Many of our companies have worked with business ethics for many years. In 2009, 63 % of our local Group companies reported having taken various measures to address business ethics issues, including procedures for segregation of duties, policies and codes, internal audits and general management procedures. Examples include Switzerland, where Feldschlösschen's top management and sales & marketing employees received training on the exchange of information and trade rival relations as well as customer and supplier relations amongst others and SEAB in Vietnam where a Business Ethics Handbook was developed for local employees.

   Another good example of existing good practices can be found in our Ukrainian Group company, Slavutich, where Business Ethics is part of the development of sales staff. In 2009, 600 sales representatives and 150 supervisors where trained in areas related to business ethics.

With the new CSR approach introduced in 2008 we identified the need to supplement and support local activities by developing a common Group-wide standard for business ethics.

A first step towards this Group-wide standard has been to create a dialogue among internal stakeholders across markets, in order to establish a common understanding of how our various companies approach business ethics issues. We did this through interviews and surveys focused on areas which are either clearly illegal or not appropriate for our company, such as bribery, corruption or the inappropriate use of our assets.

As a next step, we are developing a Business Ethics Policy which we plan to introduce in 2010, together with Guidelines, a Handbook and e-learning across the Group. By having a common Group Policy we want to promote the same standards wherever we do business.

The introduction of the new business ethics standards will be carried out by local legal counsels who align and share issues in a group-wide network. This network is a cornerstone in the further development of our work with anti-corruption measures and increasing the level of knowledge in the Group companies. By sharing best practices and identifying possible issues early, we continue to learn and improve our understanding of the global issues that are relevant to the Group.

During the year we also introduced a new CSR reporting and management system to help us collect data from the Group companies and collate these on an overall group level. This will enable us to better measure and manage our performance regarding business ethics issues.

In the new system, more than 5500 employees were reported to have received various types of training on local business ethics standards such as e-learning, presentations, workshops and induction training. The training was developed and conducted locally, with different focus areas such as competition law or anti-fraud procedures.

Going forward

  • We will work on efficient ways to communicate the Policy and Guidelines across the Group by using our local network of legal counsels and further develop training programs. We will also be introducing clear reporting procedures and performance indicators intended to improve our understanding of and approach to business ethics.

  • Our employees will be involved in global e-learning courses as a supplement to ongoing local training initiatives. Our initial focus is to first train employees in the Group who are most exposed to business ethics issues.

  • Our employees will receive a Business Ethics Handbook in order to ensure effective implementation of the Policy and to give guidance and support which can help them if they encounter a business ethics related dilemma.

  • To further promote transparency and business integrity, Carlsberg will implement a Group-wide Whistleblower system which will enable employees in the Carlsberg Group to report illegal acts, unacceptable levels of behaviour and irregularities to Group Management anonymously and without fear of reprisal.