Approach

Our Global Compliance and Ethics Department's (GC&E) mission is to promote an ethical business culture that drives company results and to mitigate risk from potential Global Code of Conduct (Code) and legal violations by maintaining an effective compliance program. Compliance with our Code as well as a commitment to acting with integrity are fundamental to doing business the right way.

Our Global Code of Conduct

We believe acting ethically and responsibly is not only the right thing to do, but also the right thing for our business. In today’s hyper-connected and transparent world, how we do things is just as important as what we do. Our Code is the foundation of our commitment to ethical excellence and provides the policies and guidelines that define how we do business. The Code outlines the company’s commitment to ethical practices in all aspects of our business:

• In the workplace;
• In the marketplace;
• In our business relationships;
• In business conduct; and
• In our world.

Operating in accordance with these principles supports sustainable growth and builds trust with our employees, consumers, investors and the communities in which we operate. For more on our core cultural values, known as The PepsiCo Way, see Employee engagement.

Our Code applies to all PepsiCo employees around the world (including employees of our consolidated subsidiaries) and members of the PepsiCo Board of Directors when they act in their capacity as directors. It is reviewed each year to reflect changes in law and is available on our internal and external websites. We acknowledge individuals who have demonstrated exceptional ethical conduct each year through peer-nominated ethical leadership awards.

Alleged violations of the Code are investigated in accordance with an incident management process and our Global Code of Conduct Escalation Policy. Confirmed violations result in corrective action or discipline, as appropriate, up to and including termination. To learn more about our Code and download it in 26 languages and dialects, please visit our Global Code of Conduct page. 

Led by the Global Chief Compliance & Ethics Officer, PepsiCo's GC&E department has primary responsibility for promoting, monitoring and enforcing compliance and ethics at PepsiCo, including the Code. GC&E accomplishes this through training designed to reinforce policies and processes that foster an ethical culture and protect against the risk of non-compliance. We place the ultimate responsibility for ethical excellence with each employee.

All compliance processes are implemented by GC&E using a risk-based approach. GC&E performs various risk assessment processes each year across all segments. Among those assessments is one performed annually at the business unit level with segment- and global roll-up. GC&E also performs different types of risk assessments as risks/priorities are identified, and GC&E conducts periodic (every 2-3 years) Functional Program Assessments, engaging outside counsel to conduct an independent assessment of PepsiCo's existing compliance program.

Compliance training and awareness

We require employees at all levels of the organization to participate in annual Code training, reinforcing awareness and understanding and reconfirming commitment to the Code. Training is available in web-based and in-person formats to ensure all employees are able to access it.

In addition to our annual training, the Code is reinforced throughout the year with local and global communications including internal articles, digital signage, portal updates, leadership messaging and ethics campaigns.  The importance of acting with integrity is also communicated by leaders at all levels across the organization through written and oral communications. Subject-matter compliance training on key risks is also conducted on a global and targeted basis.

Reporting mechanisms

We encourage employees to voice their opinion fearlessly to raise concerns about unethical business practices. All employees have an obligation to report what they suspect to be a violation of the Code, our values and policies or applicable law and can do so through any of the following channels:

• Their supervisor, manager or next level manager,
• A Human Resources manager,
• The GC&E Department,
• The PepsiCo Law Department and
• The Speak Up hotline available by phone, mobile device or online.

Speak Up hotline

Our Speak Up hotline is operated by an independent third-party vendor to provide employees, consumers, workers in our value chain, business partners and community members with a 24/7 anonymous and confidential means of reporting alleged violations of our Code or applicable law. It is accessible anywhere in the world by dedicated toll-free phone lines in more than 70 countries in multiple languages and by web in 28 languages. Speak Up is widely promoted at facilities and office locations, on company internal and external websites and in various training programs. When contacting the Speak Up hotline, an employee may remain anonymous. The same protections of confidentiality and anonymity are provided through the Speak Up program, including telephone lines and website.

All reports of suspected violations received through Speak Up are reviewed by the GC&E team in accordance with an incident management process and our Global Code of Conduct Escalation Policy. Matters are either referred for handling or assigned to investigators within each region. GC&E provides guidance and oversight to investigators to ensure investigations are conducted with the required consistency and rigor and that the appropriate corrective actions are taken. We regularly publish information on the usage of our Speak Up hotline, including the total number of reports and their categorical distribution. Our latest report can be viewed here.

Non-retaliation

PepsiCo strives to protect the rights of those individuals who report issues in good faith either through one of the reporting means described in the Code or to government authorities. The company will not retaliate or permit retaliation against a person who in good faith:

• Reports a suspected violation of our Code, our policies or the law;
• Raises a compliance question or seeks advice about a particular business practice, decision or action; or
• Cooperates in an investigation of a potential Code violation.

Retaliation against an individual for reporting an issue in good faith is itself a violation of our Code.

Anticorruption

Our ambition

Reducing the risk of corruption in our business operations is a top priority. Internal controls, systems and processes are in place to reduce the risk of corruption and bribery and to ensure our associates understand the importance of conducting PepsiCo business in compliance with all laws and regulations of the countries in which we operate and with our Code.

Our policy

At the core of our anticorruption program is our Global Anti-Bribery Compliance Policy (Anti-Bribery Policy). It prohibits any payment or any offer, promise or authorization to give anything of value to any government official or other person or entity in the private or commercial sector with intent to improperly influence a decision to obtain an unfair business advantage.

Monitoring our policy

Along with our Code, our Anti-Bribery Policy is reviewed annually and updated as necessary to reflect legislative developments, as well as internal policy and process changes. We mitigate corruption risk and monitor compliance with our Anti-Bribery Policy through systems, procedures and controls that include the following:

• Company-wide training initiatives on anti-bribery and anticorruption (ABAC);
• GC&E resources dedicated to continuous improvement of our ABAC Program;
• The requirement for PepsiCo associates to obtain prior written consent from GC&E or the Law Department for any gifts, meals, travel and entertainment for government officials or donations, sponsorships and corporate social responsibility activities to government entities or relating to government officials (subject to some limited exceptions);
• Our widely-communicated means of reporting suspected bribery and corruption to GC&E through our Speak Up hotline (see “Reporting mechanisms” above);
• Investigation of all bribery and corruption allegations in connection with the Global Code of Conduct Escalation Policy and an incident management process;
• Assessment of compliance and corruption risks through proactive integrated risk assessments conducted three times a year with Corporate Audit, GC&E and Enterprise Risk Management, which compliment annual risk assessments performed locally at the business unit level;
• Periodic reviews of PepsiCo’s ABAC program by outside counsel to identify areas for potential enhancement;
• Third-party management processes as described below;
• Anticorruption due diligence on potential mergers, acquisitions or investments;
• Requirement to include ABAC clauses in our international contracts;
• Dedicated ABAC communications initiative to generate articles on relevant ABAC topics throughout the year;
• Online and in-person employee ABAC training; and
• Third-party ABAC Training.

Anticorruption Third Party Due Diligence (TPDD) Program

PepsiCo has a risk-based third-party due diligence program, known as Third Party Due Diligence. TPDD is an important part of PepsiCo's third-party selection process. It is how we assess the reputational and corruption risks posed by certain significant third-party relationships and third-parties who interact with government officials on our behalf.

PepsiCo prohibits all forms of bribery and corruption in our operations, and we expect our third-party business partners, including suppliers, service providers, agents and contractors, to do the same. Most of our third-parties are required through mandatory contract provisions to comply with our Supplier Code of Conduct, which prohibits corruption and bribery and references the Anti-Bribery Policy. Certain international third-parties must also comply with PepsiCo’s Third Party Contract Framework for Anti-Bribery/Anticorruption, which demands a standard global approach to incorporating contractual ABAC commitments from PepsiCo’s third-parties. PepsiCo’s Anti-Bribery Policy also addresses required anticorruption due diligence processes to be conducted on third-parties. No PepsiCo employee may engage a third-party until required anticorruption due diligence processes have been completed and it has successfully gone through PepsiCo’s risk-based TPDD program.

Anticorruption training

The importance we place on maintaining an effective anticorruption program is reflected in our annual online anti-bribery training which is completed by all full-time salaried employees. The course, available in 24 languages, focuses on direct and third-party dealings with government officials (including pre-approval requirements for expenditures relating to government officials) and our TPDD program. It also includes a means for employees to disclose contacts with government officials. PepsiCo employees who engage non-frontline contractors to provide services are responsible for communicating to them the requirements of the Anti-Bribery Policy. Resources to help communicate the Anti-Bribery Policy requirements to contractors are available on PepsiCo's internal Compliance and Ethics portal. Finally, the online training also requires each employee to certify compliance with PepsiCo’s Global Anti-Bribery Compliance Policy on an annual basis.

PepsiCo also conducts live, interactive anti-bribery training sessions across the company. We take a risk-based approach to in-person training. Each segment Compliance & Ethics Officer creates a training plan to identify who will be trained in-person. The training plan includes a fixed target audience, focusing on teams/functions that likely interact with government officials as part of their standard responsibilities, plus a "non-fixed" target audience, which includes any employee who disclosed interaction with a government official during the online anti-bribery training, and other functions that address business unit specific concerns (increase in bribery or corruption-related Speak Up reports, particular geographical issues, etc.).

In 2024, we developed a new ABAC Team Communications Plan which currently publishes internally every other month. It includes topics such as Tips and Tricks for Government-related Pre-approvals, Third-party ABAC Training Overview and TPDD Efficiencies.

PepsiCo also provides third-party anti-bribery training for certain third-parties in high-corruption risk industries, specifically targeting those third-parties subject to PepsiCo’s TPDD Program.

Sanctions screening

PepsiCo seeks to conduct business in compliance with applicable trade sanctions.  Trade sanctions restrict activities with targeted countries, governments, entities, individuals and industries and are imposed by various governments and agencies, such as the U.S. Treasury Department’s Office of Foreign Assets Control, the European Union, the United Kingdom and the United Nations. PepsiCo employs a global sanctions screening process to mitigate sanctions risk, including the screening of PepsiCo’s vendors and PepsiCo’s customers with rolling annual spend/sales beyond a specified amount. Once a new third-party record is screened for sanctions, it is enrolled in ongoing sanctions monitoring. That monitoring continues on all active records up to 18 months past the last transaction date or until deactivated, whichever is sooner. In 2024, PepsiCo screened about 110,000 new third-parties and over 500,000 third-parties were subject to ongoing sanctions monitoring.

Progress

Compliance training and awareness

In 2024, approximately 93,000 salaried employees worldwide completed an online Code training course available in 24 languages and dialects certifying compliance to the Code, and about 205,000 primarily frontline employees in our plants, warehouses and sales facilities received in-person or online Code training or were provided Code learning materials.

In May 2024, a new training course titled "PepsiCo’s Ethical Sales Practices" was introduced for all employees. This training, accessible via our online learner experience platforms such as PEP U Degreed and mylearning, encompasses three essential topics that every employee involved in the marketing and sale of our products must understand: compliance with Antitrust and Fair Competition laws, understanding the restrictions and responsibilities related to trade spend and the prohibition on trade loading, also known as channel stuffing.

Additionally, over 8,000 newly hired salaried employees completed an online New Hire Code training course (which includes a section on ABAC risk) and over 25,000 employees were trained, virtually and in-person, by GC&E on topics including culture of integrity, ethical leadership, policy compliance and investigation skills.

Anticorruption training

In 2024, over 91,000 salaried employees worldwide completed an online Anti-Bribery Policy training course and certified compliance with our Anti-Bribery Policy. In addition, as part of a two-year training cycle, over 7,000 employees across the company participated in live anti-bribery training sessions led by PepsiCo legal and compliance professionals. This training sessions are interactive and address the elements of the U.S. Foreign Corrupt Practices Act in addition to country-specific laws, where appropriate.

What's next?

Looking ahead, we expect to undertake regular and continued evaluation of our GC&E Program with an eye toward continuous improvement through a focus on data, analytics and technological progress.