HEINEKEN International is a Dutch brewing company operating in 74 countries, with its products available in 178 countries. HEINEKEN has several policies regarding ethical conduct, including the Code of Business Conduct and the Employees’ & Human Rights Policy. In order to address violations of these documents and the law in general, HEINEKEN implemented the Speak Up policy. This policy outlines what employees can do if they are concerned about misconduct.
Who can access it?
The Speak Up policy is available to everyone working for or on behalf of HEINEKEN. It is also open to any party with whom HEINEKEN has or has had some type of business relationship (such as business partners, suppliers, shareholders, agents, distributors, representatives and customers).
How does it work?
The Speak Up policy can be used to raise concerns about suspected misconduct within the company, that is: any violation of the law, the Code of Business Conduct and/or the various policies and HeiRules under which HEINEKEN operates. Examples of concerns that can be raised using the Speak Up policy are:
- Discrimination and harassment
- Violations of competition laws and rules
- Inadequate financial or non-financial recordkeeping
- Conflicts of interest
- Environmental, health and safety issues
- Improper use of company resources
- Insider trading
- Disclosure of confidential information
- Violations of HEINEKEN’s policies on gifts, entertainment and hospitality
The policy cannot be used:
- To report events presenting an immediate threat to life or property.
- For any grievances in relation to terms of employment.
- To settle personal disputes.
- To make false accusations. Doing so may lead to disciplinary measures.
The Speak Up Policy is designed to make employees aware of who they can talk to when they are concerned about misconduct. Initially, there are three routes to take:
- Talk to the person involved in the misconduct.
- Talk to the line manager or to the HR representative, internal auditor or legal counsel, who can mediate on behalf of the complainant.
- Contact the trusted representative. They are there to discuss concerns in confidence and provide advice on any next steps. Trusted Representatives do not participate in any investigation so as to protect the confidentiality of conversations with them.
If the channels above prove ineffective, another option at the disposal of complainants includes:
- Reporting the suspected misconduct directly to the Business Conduct Office by sending an e-mail or a letter. In addition, The members of the Business Conduct Office can also be contacted directly. Their contact details can be found at the foot of this page.
If the employee genuinely believes that the suspected case of misconduct cannot be dealt with through the available channels above, the Speak Up Service can be used.
- The Speak Up Service allows for raising concerns confidentially and in one’s own language. This service is run by an independent third party and is available 24/7, 365 days a year. A report may be submitted through this service either by phone or online. To report misconduct by phone, the phone number of the integrity line per country can be found at speakup.heineken.com, by selecting the country of operation and ‘By phone’. The online Service is available at speakup.heineken.com, by selecting the country of operation and ‘Online’. The reporting structure will guide the complainant through the process step-by-step.
After completing a report (online or by phone), the complainant will receive a unique code called a ‘report key’. This key can be used to call back or access the website to check progress on the report, to check whether the person dealing with the report has feedback or further questions, or to provide additional information. The report key is particularly important if the complainant chooses to remain anonymous, as he/she can only be contacted through the website in that case. All reports received via the Speak Up Service are routed back to HEINEKEN for further handling.
When filing a report (in person, in writing, online or by phone), the complainant is requested to provide as much detailed information as possible to enable HEINEKEN to assess and investigate the concern. This includes:
- The background, history and reason for the concern
- Names, dates, places and other relevant information
- Any documents that may support the report
- A report can only be followed up if it contains sufficient information and there is a reasonable possibility of obtaining further information.
In the Speak Up policy, HEINEKEN states it aims to deal with any concern appropriately and confidentially. This means that any information about a concern as well as the identities of any person involved will only be shared with a limited number of people on a strict need-to-know basis. HEINEKEN is obliged to inform the implicated person that a complaint has been filed against him/her, but the identity of the complainant will not be disclosed. If desired, a complainant can report misconduct anonymously, though HEINEKEN encourages the complainant to reveal their identity in order to be better able to investigate reports. Employees who speak up are protected and any form of threat or retaliation will not be tolerated.
If a report is submitted, the complainant will receive a confirmation of receipt within 5 to 7 working days, including an estimate of how long it will take to handle and assess the concern. Depending on the nature, urgency and potential impact of the concern, the case will be handled by an Operation Company (OpCo) or Global Case Manager, who work under the supervision and instruction of the Integrity Committee. HEINEKEN follows a two-phased approach when handling concerns:
- Initial review and inquiries – The purpose hereof is to assess the concern and decide if it requires further review and investigation (and, if so, by whom and in which form). The complainant may be approached for additional information.
- Further review and investigation – If the report requires further review and investigation, a Case Manager will be assigned. The investigation itself will focus on an objective, factual analysis of the case. If needed, outside experts (e.g. lawyers or accountants) can be engaged to assist in the investigation. They will work under strict confidentiality. In addition, HEINEKEN aims to conduct all reviews and investigations in an independent, fair and unbiased manner with respect to all parties involved and in accordance with relevant laws and principles.
On average, closure of the matter can be expected within 1 to 3 months. The complainant will be informed of the overall findings, i.e. whether or not HEINEKEN has established that misconduct has taken place. HEINEKEN is not able to provide full details of the outcome of a case (or related actions taken) for reasons of confidentiality, privacy and the legal rights of all concerned.
In turn, if a complainant becomes involved in an investigation, he/she needs to cooperate and answer all questions completely and honestly. Lying to the people performing the investigation as well as delaying, interfering with or refusing to cooperate with an investigation may lead to disciplinary measures. All parties involved, including the accused, are entitled to confidentiality in order to avoid unnecessary damage to their reputation. Therefore, any complainant or anyone with information about an investigation must keep the matter confidential.
If a concern is well-founded (i.e. misconduct has indeed taken place), appropriate measures will be taken where necessary and in accordance with the law and HEINEKEN’s Policy on Disciplinary Measures.
If anyone believes that their concern or a concern raised against them has not been handled appropriately or that an investigation has not been performed correctly, this person is invited to inform the Integrity Committee at firstname.lastname@example.org or at Integrity Committee P.O. Box 28, 1000 AA Amsterdam, the Netherlands or the chairman of the Supervisory Board of Heineken N.V. at email@example.com in Integrity Committee cases.
Members of HEINEKEN Business Conduct Office
- Obbe Siderius – Business Conduct Director
Phone: +31 20 5239 253
- Vanessa Liem – Business Conduct Counsel
Phone: +31 20 5239 702
- Leonie Simons – Business Conduct Counsel
Phone: +31 20 5239 241
- Jacqueline van der Mark – Project Manager
Phone: +31 20 5239 968