Ethics and integrity

Why it matters

Approach

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.

Risk management

Led by the Global Chief Compliance & Ethics Officer, PepsiCo’s Global Compliance & Ethics (GC&E) department implements all compliance processes using a risk‑based approach. The department performs a range of risk assessment processes each year across all segments, including an annual assessment at the business unit level with a segment and global roll‑up. GC&E also performs additional risk assessments as risks and priorities emerge, and it conducts periodic Functional Program Assessments every 2–3 years, engaging outside counsel to provide an independent assessment of PepsiCo’s compliance program.

Anticorruption Third Party Due Diligence Program

PepsiCo uses a risk-based Third Party Due Diligence program (TPDD) as part of our third-party selection process. TPDD helps us assess reputational and corruption risks associated with significant third-party relationships and with third parties that interact with government officials on our behalf. PepsiCo’s Anti-bribery Compliance (ABAC) Policy outlines the anticorruption due diligence processes that apply to 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 our risk-based TPDD program.

PepsiCo prohibits all forms of bribery and corruption in our operations and expects third parties across our supply chain, including suppliers, service providers, agents and contractors, to do the same. Most third parties must comply with our Supplier Code of Conduct through mandatory contract provisions. The Supplier Code of Conduct explicitly prohibits bribery and corruption and references the ABAC Policy. Certain international third parties must also follow PepsiCo’s Third Party Contract Framework for Anti-Bribery/Anticorruption, which sets a standard global approach for contractual ABAC requirements.

Sanctions screening

PepsiCo seeks to conduct business in compliance with applicable trade sanctions. Trade sanctions restrict activities with targeted countries, governments, entities, industries, and individuals 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 2025, PepsiCo screened over 120,000 new third parties and over 570,000 third parties were subject to ongoing sanctions monitoring.

Strategy

GC&E’s 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

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 One PepsiCo Way, see Employee experience.

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 periodically to reflect changes in law and is available on our internal and external websites.

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 to download it in 27 languages and dialects, please visit our Global Code of Conduct page.

GC&E holds primary responsibility for promoting, monitoring and enforcing compliance and ethics at PepsiCo, including the Code. GC&E delivers training designed to reinforce policies and processes that foster an ethical culture and protect against the risk of non-compliance. We place the responsibility for ethical excellence with each employee. We acknowledge individuals who have demonstrated exceptional ethical conduct each year through peer-nominated ethical leadership awards.

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 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 either dedicated toll-free phone lines in over 70 countries or by web or mobile app in over 25 languages. We promote Speak Up broadly across facilities and office locations, on internal and external company websites and in training programs. Employees may remain anonymous when contacting the hotline. The Speak Up telephone lines and website provide the same protections of confidentiality and anonymity.

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.

PepsiCo’s Global Anti-bribery Compliance Policy (ABAC Policy)

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.

At the core of our anticorruption program is our ABAC 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 public or commercial sector with intent to improperly influence a decision to obtain an unfair business advantage.

Anti-bribery/Anticorruption (ABAC) Training

We place strong importance on maintaining an effective anticorruption program, which includes annual online anti-bribery training completed by all full-time salaried employees. The course, available in 24 languages, focuses on interactions with government officials through both direct and third-party dealings, including pre-approval requirements for related expenditures and our TPDD program. It also provides a channel for employees to disclose their interactions with government officials. When engaging non-frontline contractors, PepsiCo employees are responsible for communicating the requirements of the ABAC Policy to those contractors. Resources that support this communication are available on PepsiCo's internal GC&E portal. The online training also requires each employee to certify compliance with PepsiCo’s ABAC Policy each year.

PepsiCo also delivers live, interactive anti-bribery training across the company. We take a risk-based approach to in-person training. Each Segment Compliance and Ethics Officer develops a training plan that identifies the employees who will receive in-person training, which is conducted in collaboration with the Legal team. The plan includes a fixed target audience that consists of teams or functions that interact with government officials as part of their responsibilities, and a non-fixed target audience that includes any employee who disclosed interaction with a government official during the online training and other functions with business-unit specific considerations such as increases in bribery or corruption-related Speak Up reports or geographical concerns.

Third-Party ABAC training is a mandatory training for all third parties in scope for the TPDD process. It is designed to reinforce PepsiCo’s anti-bribery and anticorruption expectations with relevant third parties and is completed via a standardized, centrally managed solution. Participation is recorded in our platform and consolidated through established tracking mechanisms, enabling visibility, consistency and reporting for oversight and audit purposes.

Progress

In 2026, PepsiCo was recognized as one of Ethisphere's World's Most Ethical Companies. We are one of only six companies to receive this honor every year since its inception 20 years ago. PepsiCo’s 2024 Annual Code of Conduct training and New Hire Code of Conduct training courses received Brandon Hall Human Capital Management Excellence awards in 2025: a Silver Award for Best Compliance Training and a Gold Award for Best Custom Content, respectively.

Metrics and targets

GC&E provides training to employees year-round, both online and in-person. Enrollment for these trainings depends on factors such as employee level and classification, job duties, Speak Up trends, interactions with government officials, and ABAC risk level, among others. Training topics always include Code of Conduct and anti-bribery, with the addition of rotating topics, such as culture of integrity, ethical leadership, conflicts of interest, and policy compliance. The following metrics highlight the progress made during the year:

Actions

To meet regulatory expectations, ensure an effective compliance program and for overall continuous improvement, we regularly engage independent outside experts to assess the GC&E Program; the most recent assessment was completed in 2024.

Compliance training and awareness

In 2025, over 26,000 salaried managers completed our “Lessons on Ethical Leadership” course. Delivered via our online learning platform, MyLearning, this course emphasized what it means to be an ethical leader while exploring three major themes: respect (including stress management), balancing micro-management with empowerment (addressing insufficient oversight), and the importance of addressing concerns appropriately (with guidance on escalation procedures).

ABAC Processes

Along with our Code, we review our ABAC Policy each year and update it as needed to reflect legislative developments and internal policy or process changes. We mitigate corruption risk and monitor compliance with the ABAC Policy through systems, procedures and controls that include:

• Company-wide ABAC training
• GC&E resources dedicated to continuous improvement of our ABAC Program
• ABAC Policy Pre-Approval process that requires associates to obtain prior written consent from GC&E or the Law Department for any gifts, meals, travel or entertainment for government officials or for donations, sponsorships or corporate social responsibility activities involving government entities or government officials, subject to limited exceptions
• Widely communicated reporting channels, including the Speak Up hotline, for suspected bribery or corruption
• Investigation of all bribery or corruption allegations under 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 complement annual risk assessments at the business unit level
• Periodic reviews of the ABAC Program by outside counsel to identify potential enhancements
• Third-party management processes such as: Third-Party ABAC training assigned to Third Parties in scope for the TPDD process, with the capability to assign to out of scope third parties on an as-needed basis.
• Anticorruption due diligence on potential mergers, acquisitions or investments
• A requirement to include ABAC clauses in certain international contracts and a specific process in case exceptions are needed
• A dedicated ABAC communications initiative that publishes articles on relevant ABAC topics throughout the year, that is shared with the GC&E and Legal teams and associates, as relevant
• Online and in-person employee ABAC training

Challenges

As the business faces increasing pressure due to the challenging economic environment, employee decision making may be repeatedly tested. Given this reality, GC&E continues to emphasize ethical behavior among employees by reinforcing training initiatives and increasing communication where needed.

Ever-changing regulatory expectations require regular reevaluation of our compliance processes to help ensure that we meet the standards for an effective compliance program.

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.

¹_{These training sessions are interactive and address the elements of the U.S. Foreign Corrupt Practices Act in addition to country-specific laws, where appropriate}