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Supplier Expectations Brochure

Qualitylity - Coca-Colaassets.coca-colacompany.com/24/43/c4a775e945f09e333a95405d8d2… · he chain of value created by the Coca-Cola system begins with the ... Qualitylity. E V O

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Supplier ExpectationsBrochure

he chain of value created by the Coca-Cola system begins with the

products and services you provide to us. Delivering the highest quality requires consistent execution—by us, our bottling partners, our distributors and our retailers. But it starts with you, our suppliers.

Because quality is at the core of our business, your success is essential to our success. This second edition of the Supplier Expectations Brochure represents our commitment to working together with you toward continuous improvement and quality in everything we do.

Thank you for your commitment.

Neville IsdellChairman, Board of Directors and Chief Executive Officer of The Coca-Cola Company

T

Quality

Qualitylity

E V O L U T I O N 3 • T H E C O C A - C O L A Q U A L I T Y S Y S T E M

Quality

S U P P L I E R E X P E C T A T I O N S B R O C H U R E

E V O L U T I O N 3 • T H E C O C A - C O L A Q U A L I T Y S Y S T E M

Contents I.Introduction ......................................................................................................... 4

II.Supplier Performance Expectations ..................................................... 7

A.Quality Systems .............................................................................................. 7

B.Quality Programs ........................................................................................... 7

C.Supplier Guiding Principles .......................................................................... 10

D.Purchased Materials \ Services .............................................................. 12

E.Process Monitoring and Control .......................................................... 12

F.Finished Product Management ................................................................ 13

G.Food Safety ....................................................................................................... 14

H.Chemical Residue and Contamination Control .......................... 17

I.Traceability ........................................................................................................... 17

J.Scientific and Regulatory Affairs .............................................................. 18

K.Regulatory Actions Notification ............................................................ 19

L.Change Control Management Process ............................................. 20

M.Auditor Access ............................................................................................... 21

N.Security ................................................................................................................ 21

O.Legal Contracts............................................................................................... 23

P.Compliance with Laws ................................................................................. 24

Q.Confidentiality ................................................................................................. 24

R.Code of Business Conduct ........................................................................... 25

III.Glossary .............................................................................................................. 26

S U P P L I E R E X P E C T A T I O N S B R O C H U R E

I. IntroduCtIon

the CoCa-Cola Company exIsts to benefIt and refresh

everyone It touChes

about the CoCa-Cola Company

The Coca-Cola Company exists to

benefit and refresh everyone it touches.

More than 1 billion times every day

consumers choose our beverages for

refreshment, and they expect top quality

every time. Achieving this requires

flawless execution across the entire

supply chain, and as a supplier to the

Coca-Cola system, you play a vital role

in ensuring the quality and integrity of our

beverages. Whether you’re a current or

potential supplier of ingredients, packaging

materials, sales and marketing equipment,

or a contract packer or manufacturer,

this publication will provide you with

highlights of our supplier expectations and

authorization requirements.

The Coca-Cola Company is the world’s

leading manufacturer, marketer and

distributor of non-alcoholic beverage

concentrates and syrups, which are

used by a network of bottling partners

to produce more than 400 beverage

brands. Our corporate headquarters is

in Atlanta, Georgia, with operations in

more than 200 countries worldwide.

We serve our local markets with a wide

variety of beverages, spanning the entire

spectrum of tastes and beverage-

serving occasions. Understanding local

cultures, including preferences in work,

recreation, and relaxation activities, is

essential for developing sustainable

global business growth.

4

S U P P L I E R E X P E C T A T I O N S B R O C H U R E

E V O L U T I O N 3 • T H E C O C A - C O L A Q U A L I T Y S Y S T E M

5

QualIty In everythIng We do

For us, quality is more than just something

we taste, see or measure. Quality shows in

our every action. We relentlessly strive to

exceed the world’s ever-changing expectations,

because providing top-quality products to the

marketplace is our highest business objective.

To efficiently accomplish this, the Company

relies on the The Coca-Cola Quality System

(TCCQS). TCCQS is our branded quality

management system. Developed by a global,

cross-functional team and endorsed by senior

management of The Coca-Cola Company,

along with our top bottling partners, TCCQS

is the framework within which the Coca-Cola

system coordinates and guides its activities,

drives continuous improvement, and constantly

strives for quality in everything we do. TCCQS

supports the four principles of our corporate

citizenship framework— enriching the

workplace, providing quality in the marketplace,

preserving the environment and strengthening

the community. TCCQS reflects our integrated

approach to managing quality, the environment,

and health and safety. TCCQS incorporates

tenets of other international quality systems

like ISO 9000.

UnderstandingOurExpectations

You’ll find our supplier expectations highlighted

here in one reference. These expectations focus

on the results that must be achieved and are not

designed to be prescriptive. Although each supplier

must achieve the same end results, exactly how

that is done may vary from location to location and

from process to process.

And while delivering top-quality products is

certainly at the core of our business, there are

other expectations associated with that, such as

responsible corporate citizenship and personal

integrity.

In addition to providing top-quality beverages,

we contribute to communities around the

world through our commitment to programs

for education, health, wellness, the environment

and diversity. We strive to be a good neighbor,

consistently shaping our business decisions to

improve the quality of life in the communities

where we do business.

E V O L U T I O N 3 • T H E C O C A - C O L A Q U A L I T Y S Y S T E M

S U P P L I E R E X P E C T A T I O N S B R O C H U R E

6

You’llfindquality(foodsafety,

productintegrity)expectations

highlightedinthefollowingsections:

• Quality Systems

• Quality Programs

• Purchased Materials \ Services

• Process Monitoring and Control

• Finished Product Management

• Food Safety

• Chemical Residue

and Contamination Control

• Traceability

• Scientific and Regulatory Affairs

• Security

Corporatecitizenshipexpectations

suchasemploymentpractices,

workplacesafetyandenvironmental

practicesareinthefollowingsection:

• Supplier Guiding Principles

Communicationexpectationsarein

thefollowingsections:

• Regulatory Actions Notification

• Change Control Management Process

• Auditor Access

• Legal Contracts

• Compliance with Laws

• Confidentiality

Expectationsregardinghonestyand

integrityinday-to-dayactivitiesare

inthefollowingsection:

• Code of Business Conduct

Our local Company divisions or individual

receiving locations (such as bottling plants)

may also have business or plant-specific

expectations. These should be clearly

communicated to you as part of the

procurement process.

S U P P L I E R E X P E C T A T I O N S B R O C H U R E

E V O L U T I O N 3 • T H E C O C A - C O L A Q U A L I T Y S Y S T E M

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II. supplIer performanCe expeCtatIons

A. Quality Systems

Policy

Suppliers must have an effectively

implemented quality system that ensures

consistent delivery of high-quality products

and services to the Coca-Cola system

(The Coca-Cola Company and its bottling

partners).

Definitions

QualitySystem:

(1)A collection of procedures, activities,

organizational structures and engineering

controls (both formal and informal)

employed to respond to applicable

requirements by directing and regulating

quality assurance activities.

(2)The organizational structure,

responsibilities, procedures, processes and

resources needed for implementing quality

management. Organizational structure,

policies, programs and procedures needed

to manage product safety and quality.

Requirements

The quality system must be documented.

The system must include policies, programs

and procedures that are designed to ensure

compliance with The Coca-Cola Company

specifications, regulatory requirements and

the expectations outlined in this brochure.

There must be a process in place to ensure

the most current policies, programs, formulas

and procedures are properly distributed to

functional areas of the supplier’s facility.

Periodic audits of the quality system must

be conducted by the supplier in order to

verify the system’s effectiveness as well as to

identify opportunities for improvement.

B. Quality Programs

Policy

Suppliers must effectively implement the

quality programs outlined in this section as

part of their quality system.

Definition

QualityProgram:An individual

component of the overall quality system

that is designed and implemented to

address a specific set of quality issues, risks

or concerns. A quality program can include

a broad collection of procedures, activities,

organizational structures and engineering

controls.

S U P P L I E R E X P E C T A T I O N S B R O C H U R E

8

Requirements

Quality Programs that must be in place

include, but are not limited to, the

following:

ConformancetoSpecifications

At a minimum, suppliers to

The Coca-Cola Company must have policies

and procedures in place to ensure that

products provided to The Coca-Cola

Company meet specifications.

GoodManufacturingPractice

At a minimum, all plant personnel, visitors and

outside contractors must comply with Good

Manufacturing Practice (GMP) requirements

as set forth by current laws and regulations.

In the absence of local laws and regulations,

use Good Manufacturing Practice (Title 21,

Part 110 – United States Code of Federal

Regulations or current European Union Food

Safety Guidelines) as a reference.

GMP relates to the manufacturing,

processing and storing of food materials

to assure the food materials are safe

for human consumption and have been

prepared, packed and stored under sanitary

conditions. This includes the prevention of

any type of contamination. Good

Manufacturing Practice requires

correctly designed and constructed

buildings and equipment,

adequate training of personnel

to produce quality food materials

and properly maintained plant

conditions.

GoodLaboratoryPractice

Good Laboratory Practice (GLP) embodies a

set of principles that provides a framework in

which laboratory tests are planned, performed,

monitored, recorded, reported and archived.

These tests are undertaken to generate

data to assess the hazards and risks to users,

consumers and third parties (including the

environment), of exposure to pharmaceuticals,

agrochemicals, cosmetics, food and feed

additives and contaminants, novel foods

and biocides. GLP helps assure regulatory

authorities that the data submitted is a true

reflection of the results obtained during the

testing and can therefore be relied upon when

making risk \ safety assessments.

All plant and contract laboratories and

laboratory personnel must implement GLP

principles based upon current laws and

regulations. In the absence of local laws and

regulations, use Good Laboratory Practice

(Title 21, Part 58 - United States Code of

Federal Regulations or current European

Union Food Safety Guidelines) as a reference.

The laboratory must use published,

recognized and validated testing methods.

Where published test methods are not

available, internally developed

methods must be validated for

their intended use consistent with

GLP requirements. The way the

lab is equipped, arranged and

managed must ensure test results

are consistent and reliable.

E V O L U T I O N 3 • T H E C O C A - C O L A Q U A L I T Y S Y S T E M

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PersonnelTraining

Suppliers must have planned, functional

and effective training processes for

employees who have responsibility for

controlling, manufacturing, moving or

storing products for The Coca-Cola

Company.

Suppliers must ensure all permanent

and contract employees are trained,

qualified and skilled to perform their

assigned responsibilities.

PestControl

A documented pest control program must

be in place to effectively prevent pest

activity in the facility and/or surrounding

area. This program must be managed by

trained plant personnel. Pest control

activities must be performed by certified

pest control operators or personnel with

equivalent training.

Use of all insecticides, fungicides or

rodenticides must be in accordance with

current local laws and regulations of the

location where products are produced as

well as the laws and regulations of the

destination to which the products may be

delivered. Technical supplements may specify

other requirements.

HousekeepingandSanitationControls

A documented sanitation and housekeeping

program must be in place that meets all

regulatory requirements and ensures

the cleanliness of the food handling

equipment and the facility. The program

must also ensure that all ingredients,

packaging, in-process components and

finished goods storage areas, shipping

trailers, cars and containers are clean and

pest-free.

Only cleaning chemicals that are approved

for use in food manufacturing facilities are

permitted to be used for the specific

purpose intended. Programs for managing

facility housekeeping must be included in

the supplier’s plant sanitation controls. A

system for verifying and documenting the

effectiveness of the sanitation program must

be in place.

FacilitiesandEquipmentDesign

Facilities and equipment used to

manufacture, handle or store materials

must be appropriately designed and suitable

for their intended use.

Facilities and equipment must be maintained

to preclude potential contamination by or

exposure to outside elements, odorous

substances, pests, hazardous materials and

microbial contaminants.

S U P P L I E R E X P E C T A T I O N S B R O C H U R E

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RecordKeeping

Suppliers must design and implement a

program that ensures that records are

adequate, confirm adherence to specified

standards and demonstrate quality

system effectiveness.

Records must be maintained, legible, readily

identifiable and retrievable.

Corrective\PreventiveActionProgram

Each facility must design and implement a

corrective \ preventive action program that

ensures action is taken to eliminate the

cause of existing and potential non-

conformances in order to prevent

occurrence \ recurrence. The corrective

action program must be evaluated

periodically to drive continuous

improvement, and corrective actions

that are taken as a result of the program

must be reviewed to ensure effectiveness.

C. Supplier Guiding Principles

Policy

Suppliers to The Coca-Cola Company

must support fair employment practices

consistent with a commitment to human

rights in the workplace and provide a safe

working environment. Suppliers to and

suppliers authorized by The Coca-Cola

Company must abide by all applicable laws,

including local laws addressing working

hours, compensation, employees’ right to

choose whether to be represented by

a third party and to bargain collectively,

working conditions and other such

workplace practices.

Requirements

At a minimum, suppliers to The Coca-Cola

Company and suppliers authorized by The

Coca-Cola Company will be required to

meet the following standards with respect

to their operations, as a whole:

• LawsandRegulations - Supplier will

comply with all applicable laws, rules,

regulations and requirements in the

manufacture and distribution of our

products and supplies and in providing

services to The Coca-Cola Company.

• ChildLabor - Supplier will not use

child labor as defined by local law.

• ForcedLabor - Supplier will not use

forced or compulsory labor.

• AbuseofLabor - Supplier will not

physically abuse labor.

E V O L U T I O N 3 • T H E C O C A - C O L A Q U A L I T Y S Y S T E M

11

• FreedomofAssociation&

CollectiveBargaining - Supplier

will comply with all applicable local

laws on freedom of association and

collective bargaining.

• Discrimination - Supplier will

comply with all applicable local

discrimination laws.

• WagesandBenefits - Wages and

benefits will comply with local law.

• WorkingHoursandOvertime -

Working hours and overtime will

comply with local law.

• HealthandSafety - Working conditions

will comply with local regulations.

• Environment - Supplier will comply

with all applicable environmental laws.

These minimum requirements are part

of all new or renewed commercial

agreements between The Coca-Cola

Company and its direct suppliers.

Suppliers must be able to demonstrate

their compliance with these requirements

at the request of and to the satisfaction of

The Coca-Cola Company. The Coca-Cola

Company has the right to inspect any site

involved in work for The Coca-Cola

Company.

Any supplier that fails to satisfy

The Coca-Cola Company of its compliance

is subject to termination of any agreements

between it and The Coca-Cola Company

and its subsidiaries, without penalty

to The Coca-Cola Company and its

subsidiaries, but with obligations to

remedy direct damages suffered by

The Coca-Cola Company and its subsidiaries.

S U P P L I E R E X P E C T A T I O N S B R O C H U R E

12

D. Purchased Materials \ Services

Policy

Suppliers must have controls in place to

ensure purchased materials and services

comply with specifications and applicable

laws and regulations.

Definitions

ApplicableLawsandRegulations: The

laws and regulations governing the location

in which products are produced, the

laws and regulations of the destination to

which products may be delivered, and the

laws and regulations of the United States

pertaining to embargo, economic and trade

sanctions, and specially designated nationals

(SDNs) or blocked persons. A list of SDNs

and blocked persons is maintained on the

United States Department of Treasury Web

site at:

www.treas.gov/offices/enforcement/ofac/sdn.

PurchasedMaterials\Services: Materials

or services purchased by suppliers for use in the

production of their finished products.

Requirements

A program must be in place to approve and

monitor the performance of suppliers of

purchased materials.

Suppliers must have written specifications

for purchased materials. Specifications must

be written in accordance with applicable

laws and regulations as well as the

requirements of The Coca-Cola Company.

Suppliers warrant that materials \ services

purchased from their approved suppliers

must meet specifications that have

been established.

A system must be in place to prevent the

use of purchased materials that do not

meet specifications.

E. Process Monitoring and Control

Policy

Suppliers must design and implement a

process monitoring and control program

E V O L U T I O N 3 • T H E C O C A - C O L A Q U A L I T Y S Y S T E M

13

that ensures all products are manufactured

in compliance with The Coca-Cola

Company specifications.

Requirements

Suppliers must clearly define the process used

to convert raw materials into finished

products. This must include the identification of

inputs, outputs and control points (including

monitoring frequencies) for each process.

Suppliers must monitor all processes to

ensure that they are operating properly

and are under control, for example: use of

monitoring and recording devices, use of

statistical process control tools, and the like.

CalibrationControls

Suppliers must identify critical processing

and testing equipment and design and

implement a calibration program for that

equipment that ensures the accuracy and

validity of results. The program must include

procedures for monitoring the performance

of processing and testing equipment to

ensure that the equipment continues to

perform between calibrations.

Weight\FillControls

Suppliers must have a weight \ fill control

program that complies with all applicable

regulatory and The Coca-Cola Company

requirements.

The weight \ fill control program must

include routine scale calibration and

corrective action plans.

F. Finished Product Management

Policy

Suppliers must have a program in place to

ensure all finished products are handled in

a manner that protects their quality and

integrity. In addition, suppliers must have

controls in place to prevent the shipment

of non-conforming products.

Definitions

FinishedProduct:Product, equipment,

packaging material or ingredient created

by a supplier’s manufacturing process for

use by The Coca-Cola Company.

S U P P L I E R E X P E C T A T I O N S B R O C H U R E

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Hold: The quarantine, segregation or

containment of materials to prevent their

fur ther use or distribution.

NonconformingProduct: Product,

equipment, packaging material or

ingredient that fails to meet specifications

or regulatory requirements.

Requirements

DesignofStorageFacilities

Facilities used for the handling or storing

of materials and components must be

appropriately designed and suitable for

their intended use. (See Housekeeping

and Sanitation Controls on page 9.)

Transportation

Processes must be in place to prevent the

shipment of non-conforming products.

Suppliers must inspect all transportation

vehicles for structural integrity, cleanliness and

suitability prior to loading. Tankers must

be dedicated for food-grade materials.

Documentation showing the previous

products shipped and tanker cleaning must be

available.

PackagingStandard

All finished products must be palletized

unless otherwise specified. Pallets must be

made of suitable material and must be

clean, dry and free from contaminants

(such as insecticides, fungicides, pesticides

or other chemicals). Wood pallets must

be kiln dried.

Finished product packaging standards

must be approved by the customer. Any

variation, including pallet wood types,

must be agreed to and approved by The

Coca-Cola Company.

NonconformingProducts

Nonconforming products must be segregated

or identified by physical location \ storage,

markings, authorized stamps, tags, labels,

inspection records, inventory systems or

other suitable means to ensure the

prevention of dispatch.

Procedures for rework, disposal and/or

change of final use of the nonconforming

products must be in place and records for full

traceability must be maintained.

G. Food Safety

Policy

Suppliers of food-grade materials must

implement a food safety protection program,

based upon the principles of Hazard

E V O L U T I O N 3 • T H E C O C A - C O L A Q U A L I T Y S Y S T E M

15

Analysis Critical Control Point (HACCP), to

ensure the wholesomeness and safety of

their products.

TCCQS incorporates the tenets of CODEX

HAACP and other international food safety

standards and programs like ISO 22000.

Suppliers of food product processing or

handling equipment must implement a food

safety protection program based upon the

principles of HACCP or the equivalent that

follows local regulations and requirements

applicable to equipment in contact with

food products.

Definitions

HACCP: Hazard Analysis Critical

Control Point is a broadly recognized

preventive and systematic approach for the

identification, evaluation and control of food

safety hazards.

Hazard: A biological, chemical or physical

agent or factor with the potential to cause

an adverse health effect that is likely to

occur in the production process if control is

not exercised.

FoodAllergens: Foods or food

constituents known to produce allergic

reactions to an at-risk portion of

the population.

ForeignMaterial: Any material that is

not natural to the product, such as metal,

wood, glass, plastic, rock, paper or cloth.

ExtraneousMaterial: Any undesirable

material that is a natural part of the

product, such as stems, leaves and seeds.

Requirements

If applicable, the supplier must have a

documented food safety protection

program that eliminates or reduces any

food safety hazard to an acceptable level.

An effective food safety protection

program consists of the following:

1. Definition of hazards and risks

2. Identification of Critical Control

Points (CCPs)

3. Critical limits for each CCP

4. Description of the monitoring

procedure for each CCP

5. Description of corrective actions

when there is a noncompliance

at a CCP

S U P P L I E R E X P E C T A T I O N S B R O C H U R E

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6. An effective records system

7. A system to routinely verify, or audit,

the food safety protection program

to ensure effectiveness

The types of hazards the supplier must

take into consideration include any

biological, chemical or physical agent or

factor with the potential to cause an

adverse health effect.

A plan must be in place to eliminate,

reduce, control to a safe level and to

monitor all hazards.

Suppliers must have controls for the

following hazards as part of their food

safety protection program:

• Food allergens

• Foreign and extraneous materials

FoodAllergenControl

Suppliers must have controls in place to

prevent the presence of undeclared food

allergens. The primary potential food

allergens* include, but are not exclusive to,

the following:

• Celery and products thereof

• Eggs and products thereof

• Milk and products thereof (including

lactose)

• Mustard and products thereof

• Peanuts and products thereof

• Crustaceans (shellfish) and products

thereof

• Fish and products thereof

• Sesame seeds and products thereof

• Tree nuts and products thereof

• Wheat and cereals containing gluten

• Sulfites

* Additional food allergens may be

added to this list as their public health

importance becomes recognized.

Suppliers must ensure that no

undeclared ingredient will be introduced

into a product by any means of

cross contamination.

Raw materials, processing aids and packaging

materials used in the production of each

product must be reviewed to determine if

food allergens are present. If present, they

must be declared.

Food allergens present in products that

are in-process must be properly identified.

Controls must be in place to prevent cross

contamination from these products and to

highlight their presence to the workforce.

E V O L U T I O N 3 • T H E C O C A - C O L A Q U A L I T Y S Y S T E M

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ForeignandExtraneous

MaterialControl

Suppliers must conduct a risk assessment

to identify potential foreign or extraneous

material hazards.

Suppliers must have controls, procedures

and equipment in place to prevent foreign

and extraneous material from entering

their products. Examples include the use

of metal detectors, magnets, screens and filtration systems.

H. Chemical Residue and Contamination Control

Policy

Suppliers must ensure that only legally

permitted and Coca-Cola Company

specified chemicals, ingredients and

additives are present in their finished

products.

Requirements

Controls must be implemented and

documented to ensure that only legally

permitted chemical agents are used.

Universally accepted agronomic practices,

including integrated pest management

strategies, should be used to produce quality products.

I. Traceability

Policy

Suppliers must have a system in place to

identify and trace all products, ingredients,

components, raw materials and goods in

progress.

Definitions

Lot: A supplier-defined quantity of a

product.

LotRecords: A collection of records \ data

that identifies the complete history of a lot.

This includes procurement,

manufacturing, testing and

shipping information to

enable traceability.

S U P P L I E R E X P E C T A T I O N S B R O C H U R E

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MockRecallorSimulatedProduct

Recovery:A simulated recall of the

manufactured product or item, including the

tracing of all manufacturing records, all shipping

records and a full reconciliation of quantities

received, manufactured, stored and shipped.

SerialNumber:An alphanumeric code

assigned by a supplier to identify a single

product unit, for example: a piece of

equipment, a container, a pallet or the like.

Requirements

A system must be in place that enables the

supplier to trace the entire history of a specific

lot. This includes identification of all materials

(including any rework added), processing

conditions, test results and the customers to

whom the lot was distributed.

Suppliers must uniquely identify each lot.

(Note: All traceability rules described for a lot

are applicable for a serial number.)

The traceability process must be validated

through a mock recall system to verify

effectiveness.

J. Scientific and Regulatory Affairs

Policy

Suppliers must provide complete and

accurate information to ensure the safety

and legality of The Coca-Cola Company

products.

Requirementsfor

IngredientSuppliers

For new ingredients or upon request,

suppliers must provide complete and

accurate information on forms that will be

provided by The Coca-Cola Company that

include the following:

• Qualification Packet for New

Ingredients (includes, but is not

limited to religious certifications, food

allergen declarations, certificates of

legality, certificate of origin, customs

classifications)

• Ingredient Composition Information

(includes sources of caloric content)

• Vitamin Composition Information

for added vitamins

• Nutritional Information sheet

(provided upon request)

• Material Safety Data Sheet (MSDS)

with hazardous component

declarations

• European Union non-GMO statement

(required for Europe and the Middle

East; based on EU genetically modified

organisms directives)

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FacilityRegistration

• All United States-based facilities that

produce and/or store food, feed and

ingredients must register with the

Food and Drug Administration (FDA).

• All foreign-based facilities that produce

and/or store food, feed and ingredients

that are imported into the United

States must register with the FDA.

PriorNotice

• Facilities must provide the FDA “prior

notice” of every shipment of food,

feed and ingredient imported into the

United States. This regulation affects

facilities that ship samples to the

United States.

RequirementsforPackagingand

SalesEquipmentSuppliers

Materials include any raw materials and

components used in the manufacturing of

packaging and sales equipment.

• Materials used in the manufacturing

of packaging and sales equipment

must meet both corporate and

local division requirements and

performance criteria established

for packaging materials and sales

equipment.

• Materials used must meet

The Coca-Cola Company policy

on heavy metals.

• Materials that have a potential

for direct contact with

product must comply with all

local regulatory requirements for

food contact use in the country in

which the finished product will be

distributed.

• Suppliers must provide complete

and accurate information for all

components of materials used for

contact with product.

K. Regulatory Actions Notification

Policy

Suppliers must notify The Coca-Cola

Company of any regulatory actions or

product retrievals that relate to materials

produced for the Coca-Cola system.

S U P P L I E R E X P E C T A T I O N S B R O C H U R E

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Definitions

RegulatoryAuthority: Any duly authorized

agent or employee of any government agency

empowered to enforce laws.

ReligiousAuthority:Any duly authorized

agent or employee of a religious organization

that defines requirements for special product

certification (for example, halal, kosher).

RegulatoryAction: The seizure, holding

or recall of any product by a regulatory

authority. Also includes any findings resulting in

prosecution, injunction or a regulatory letter.

ProductRecall: Any voluntary or

involuntary recovery of product that has

been released for distribution.

Requirements

Suppliers must immediately notify The

Coca-Cola Company representative and

receiving location(s) in writing when any

product or component produced for the

Coca-Cola system is directly or indirectly

the subject of a regulatory action, product

recall or when there is an event that could

create adverse publicity to the Coca-Cola

system. This includes, but is not limited to,

product that does not comply with the

following:

• Standards of quality

• Specifications

• Laws or regulations

• Agreements between the supplier and

The Coca-Cola Company or other entities within the Coca-Cola system

L. Change Control Management Process

Policy

Suppliers must have a documented change

control management process. Suppliers

must notify The Coca-Cola Company

of any changes that may impact the

quality, regulatory status, integrity and/or

performance of their product.

Requirements

At a minimum, suppliers to The Coca-Cola

Company must document and implement

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a change control management process that

ensures changes that impact product quality

are reviewed, verified and approved before

implementation. Records of the changes

must be maintained and available for review

by The Coca-Cola Company upon request.

The Coca-Cola Company must be notified

when any changes occur to the following:

• Manufacturing process (outside

of normal operating conditions)

• Manufacturing location

• Packaging

• Product formula \ specifications

• Company \ facility ownership

Notification must be made in writing and

agreed to by The Coca-Cola Company prior

to product shipment.

M. Auditor Access

Policy

Suppliers must permit auditor access to

facilities used to manufacture, pack or store

products for the Coca-Cola system.

Requirements

At any time, representatives of the

Coca-Cola system must be allowed

to enter and audit/inspect any facility

manufacturing and/or storing materials for

the Coca-Cola system.

It is the practice of the Coca-Cola system

to give reasonable notice of intent to

conduct an audit or inspection.

Limitations

An audit or inspection will not extend to

financial data, sales data (other than data

that directly relates to The Coca-Cola

Company), pricing data or personnel data

(other than data related to qualifications

of technical and professional personnel

performing functions pertinent to the

audit or governmental requirements with respect to personnel practices).

N. Security

Policy

Suppliers must have a security policy that is

designed to protect the materials supplied to

the Coca-Cola system and to minimize risks

to personnel, trademarks and facilities.

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Definitions

TamperEvident: A feature of a package

or container that allows consumers, under

ordinary conditions of use, to determine

whether unauthorized opening or

tampering has occurred.

Tamper-EvidentSeal: Seals or sealing

mechanisms that are unique to the supplier,

and are non-toxic and designed to readily

show any violation or attempted violation

of the integrity of the seal or a change in

status of the package or object on which

they are placed; such as containers or

valves. For suppliers, seals should be unique

and identifiable to that specific supplier.

The design and strength of the seals used

depend on the specific use of the seal

and the risk inherent with inadvertent

damage or violation of the seal’s integrity.

For example, plants bulk-shipping Company

products should select stronger high-tensile

strength numbered seals for protection.

IntellectualProperty:All works,

including literary works, pictorial, graphical

and sculptural works, architectural works,

works of visual arts and any other work

that may be the subject matter of copyright

protections; advertising and marketing

concepts; information; data; formulas; designs;

models; drawings; computer programs,

including all program documentation, related

listings, design specifications and flowcharts;

trade secrets; and any inventions, including

all processes, machines, manufactures and

compositions of matter and any other

invention that may be the subject matter

of patent protection; and all statutory

protection obtained or obtainable thereon.

Requirements

AuthorizedSuppliers

Suppliers to the Coca-Cola system must

be duly authorized by The Coca-Cola

Company prior to supplying beverage

products, packaging, ingredients, sales and

marketing equipment and processing aids.

Every supplier plant location needs to be

authorized by every division to which it

supplies materials. This authorization must

include every item that is being supplied

by the plant location. In addition, for packaging

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and sales and marketing equipment suppliers,

all materials that have product contact

or potential product contact must be formally

approved by corporate headquarters and

authorized by the receiving division for

supplier use. Authorization includes

compliance with the requirements and

standards listed below.

SecurityPolicy

Suppliers must have a written security

policy under the management of a designated

individual who can satisfactorily demonstrate

compliance to that policy. For products

delivered by suppliers to Coca-Cola system

locations in the United States (including

Puerto Rico), suppliers must be members of

the United States Customs and Border

Protection’s Customs-Trade Partnership

Against Terrorism (C-TPAT) or otherwise

comply at all times with C-TPAT

security criteria.

TrademarkProtection

Suppliers must maintain control of The Coca-Cola Company trademarked

materials, promotional materials and/or

graphics (“Intellectual Property”) until point of

delivery. This requirement includes the control,

use and destruction of scrap and/or obsolete

materials. Suppliers must acknowledge and

comply with requirements pertaining to

The Coca-Cola Company’s intellectual

property ownership rights at all times.

TamperEvidence

Beverages, packaging, ingredients and

processing aids must be supplied in suitable

tamper-evident packaging authorized by

The Coca-Cola Company or in

appropriately security-sealed bulk

containers \conveyances.

Information

Suppliers must secure access to

information under their control that

pertains to the Coca-Cola system,

including production, warehousing and

transportation manifests as well as

transactional documentation \ records.

LocalRegulations\Requirements

Suppliers must be able to demonstrate,

to the satisfaction of The Coca-Cola

Company, that they are in compliance with

all applicable local security laws and regulations

and any local requirements of

The Coca-Cola Company.

O. Legal Contracts

Policy

Unless otherwise approved by the

purchasing entity, purchases of goods and

services made by the Coca-Cola system

must be governed by a purchase contract.

Examples of purchase contracts include,

but are not limited to, the following: master

supply agreements, supply agreements and

purchase orders. In some circumstances,

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additional terms and conditions may

be required to govern our business

relationship with a supplier. For example,

an authorization agreement (sometimes

known as a Manufacturer’s Authorization

Agreement, or MAA) between

The Coca-Cola Company and suppliers may

be required, particularly when the supplier

is providing packaging or sales and

marketing equipment with one or more

Company trademarks and/or

The Coca-Cola Company does not have a

direct supply relationship with the supplier.

P. Compliance with Laws

Policy

The supply of goods and services to the

Coca-Cola system must comply with

applicable laws and regulations.

Definitions

OFAC: The United States Department of

Treasury’s Office of Foreign Assets Control.

SDNs: The list of specifically designated

nationals or blocked persons as maintained

by OFAC.

Embargoed\SanctionedCountries: Any country subject to an embargo or

economic or trade sanctions by the United

States Government.

Requirements

In addition to the requirements to comply

with specific laws identified elsewhere in

this document and the general requirement

to comply with applicable laws and

regulations, suppliers must not be:

• identified as specially designated

nationals;

• directly or indirectly owned or

controlled by the government of any

embargoed \ sanctioned countries;

• acting on behalf of any embargoed \

sanctioned countries;

• involved in business arrangements or

otherwise engaged in transactions with

embargoed \ sanctioned countries

(unless such arrangements or

transactions are permitted by a current

and valid license issued by OFAC); or

• sourcing any products or services

used in the supply of products or

services to the Coca-Cola system from

embargoed \ sanctioned countries.

Suppliers must notify The Coca-Cola

Company immediately and in writing

upon the occurrence of any of the

circumstances described above.

Q. Confidentiality

Policy

Suppliers must maintain confidentiality of

The Coca-Cola Company information.

Requirements

At the request of The Coca-Cola Company,

suppliers must enter into a nondisclosure

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Comment

The Coca-Cola Company expects all of its

employees to comply with the law and act

ethically in all matters. We have the same

expectations of our suppliers. Our Code of

Business Conduct sets the basic standards

for employee conduct. This Code of

Business Conduct for Suppliers establishes

related requirements for our suppliers.

Working together, we can achieve great

success by doing the right thing.

OurCodeofBusinessConductfor

Suppliersisavailableinthefollowing

languages:

• Arabic • Japanese

• English • Portuguese

• French • Russian

• German • Simplified Chinese

• Italian • Spanish

*You will find an electronic version of the

Code of Business Conduct for Suppliers at:

http://www.thecoca-colacompany.com/

citizenship/supplier_code.html

Requirement

Suppliers must act in a manner that is

consistent with the requirements of

The Coca-Cola Company Code of Business

Conduct for Suppliers.

agreement or other agreement containing

confidentiality obligations appropriate

for the safeguarding of The Coca-Cola

Company’s confidential information.

Except as otherwise set forth in such an

agreement, the safeguarding of

The Coca-Cola Company’s confidential

information includes, but is not limited to,

the following:

• Restricting the disclosure of confidential

information only to employees who

have a need to know

• Safeguarding confidential information to

prevent disclosure to any third party

• Returning all confidential information

(including copies) and erasing all

electronic information within 30 days

of the receipt of a written request by

The Coca-Cola Company

• Refraining from publishing or using,

without prior written consent, any

advertising, sales promotion, mailing

or publicity matter that mentions or

implies The Coca-Cola Company or

its subsidiaries, parents, affiliates and/or

authorized bottling partners

R. Code of Business Conduct for Suppliers

Policy

Suppliers must understand and comply with

The Coca-Cola Company Code of Business

Conduct for Suppliers*.

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ApplicableLawsandRegulations: The laws and regulations governing the location in which products are produced, the laws and regulations of the destination to which products may be delivered, and the laws and regulations of the United States pertaining to embargo, economic and trade sanctions, and specially designated nationals (SDNs) or blocked persons. A list of SDNs and blocked persons is maintained on the United States Department of Treasury Web site at: www.treas.gov/offices/enforcement/ofac/sdn.

AuthorizedSupplier: A company authorized in writing by The Coca-Cola Company, or its designee, to supply a product or a service to the Coca-Cola system (Company, authorized bottling partners and customers authorized by the Company).

Coca-ColaTrademarkBrandProducts:Products bearing the Coca-Cola trademark in their name, such as Coca-Cola, Coca-Cola classic, cherry Coke, Diet Coke and Coca-Cola light.

Embargoed\SanctionedCountries: Any country subject to an embargo or economic or trade sanctions by the United States Government.

ExtraneousMaterial: Any undesirable material that is a natural part of the product, such as stems, leaves and seeds.

FinishedProduct:Product, equipment, packaging material or ingredient created by a supplier’s manufacturing process for use by The Coca-Cola Company.

FoodAllergens:Foods or food constituents known to produce allergic reactions to an at-risk portion of the population.

ForeignMaterial: Any material that is not natural to the product, such as metal, wood, glass, plastic, rock, paper or cloth.

GoodLaboratoryPractice(GLP): Good Laboratory Practice (GLP) embodies a set of principles that provides a framework in which laboratory tests are planned, performed, monitored, recorded, reported and archived. These tests are undertaken to generate data to assess the hazards and risks to users, consumers and third parties (including the environment), of exposure to pharmaceuticals, agrochemicals, cosmetics, food and feed additives and contaminants, novel foods and biocides. GLP helps assure regulatory authorities that the data submitted is a true reflection of the results obtained during the testing and can therefore be relied upon when

making risk \ safety assessments.

GoodManufacturingPractice(GMP): GMP relates to the manufacturing, processing and storing of food materials to assure the food materials are safe for human consumption and have been prepared, packed and stored under sanitary conditions. This includes the prevention of any type of

III. glossary

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contamination. Good Manufacturing Practice requires correctly designed and constructed buildings and equipment, adequate training of personnel to produce quality food materials and properly maintained plant conditions.

HACCP: Hazard Analysis Critical Control Point is a broadly recognized preventive and systematic approach for the identification, evaluation and control of food safety hazards.

Hazard: A biological, chemical or physical agent or factor with the potential to cause an adverse health effect that is likely to occur in the production process if control is not exercised.

Hold: The quarantine, segregation or containment of materials to prevent their further use or distribution.

IntellectualProperty: All works, including literary works, pictorial, graphical and sculptural works, architectural works, works of visual arts and any other work that may be the subject matter of copyright protections; advertising and marketing concepts; information; data; formulas; designs; models; drawings; computer programs, including all program documentation, related listings, design specifications and flowcharts; trade secrets; and any inventions, including all processes, machines, manufactures and compositions of matter and any other invention that may be the subject matter of patent protection; and all statutory protection obtained or obtainable thereon.

Lot: A supplier-defined quantity of a product.

LotRecords: A collection of records \ data that identifies the complete history of a lot. This includes procurement, manufacturing, testing and shipping information to enable traceability.

MockRecallorSimulatedProductRecovery: A simulated recall of the manufactured product or item, including the tracing of all manufacturing records, all shipping records and a full reconciliation of quantities received, manufactured, stored and shipped.

NonconformingProduct: Product, equipment, packaging material or ingredient that fails to meet specifications or regulatory requirements.

OFAC: The United States Department of Treasury’s Office of Foreign Assets Control.

ProductRecall: Any voluntary or involuntary recovery of product that has been released for distribution.

PurchasedMaterials\Services: Materials or services purchased by suppliers for use in the production of their finished products.

QualityProgram: An individual component of the overall quality system that is designed and implemented to address a specific set of quality issues, risks, or concerns. A quality program can include a broad collection of procedures, activities, organizational structures and engineering controls.

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QualitySystem: (1) A collection of procedures, activities, organizational structures, and engineering controls (both formal and informal) employed to respond to applicable requirements by directing and regulating quality assurance activities. (2) The organizational structure, responsibilities, procedures, processes, and resources needed for implementing quality management. Organizational structure, policies, programs and procedures needed to manage product safety and quality.

RegulatoryAction: The seizure, holding or recall of any product by a regulatory authority. Also includes any findings resulting in prosecution, injunction or a regulatory letter.

RegulatoryAuthority:Any duly authorized agent or employee of any government agency empowered to enforce laws.

ReligiousAuthority: Any duly authorized agent or employee of a religious organization that defines requirements for special product certification (for example, halal, kosher).

SDNs: The list of specifically designated nationals or blocked persons as maintained by OFAC.

SerialNumber:An alphanumeric code assigned by a supplier to identify a single product unit, for example: a piece of equipment, a container, a pallet or the like.

TamperEvident: A feature of a package or container that allows consumers, under ordinary conditions of use, to determine whether unauthorized opening or tampering has occurred.

Tamper-EvidentSeal: Seals or sealing mechanisms that are unique to the supplier, and are non-toxic and designed to readily show any violation or attempted violation of the integrity of the seal or a change in status of the package or object on which they are placed; such as containers or valves. For suppliers, seals should be unique and identifiable to that specific supplier. The design and strength of the seals used depend on the specific use of the seal and the risk inherent with inadvertent damage or violation of the seal’s integrity. For example, plants bulk-shipping Company products should select stronger high-tensile strength numbered seals for protection.

TheCoca-ColaCompany:The legal entity entitled “The Coca-Cola Company” and its CONSOLIDATED AFFILIATES. It includes all internal BUSINESS UNITS, such as COMPANY OPERATING GROUPS, DIVISIONS, REGIONS and CONSOLIDATED BOTTLING OPERATIONS, and all fur ther subsets of these units.

TheCoca-ColaSystem: The Coca-Cola Company and its BOTTLING PARTNERS

TrademarkedMaterial:Business-related articles, including, packaging materials, labels, seals, and closures, that bear the trademarked logos of The Coca-Cola Company.