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Our Integrated Governance Approach

Sürdürülebilirlik Yönetimi

Sürdürülebilirlikte Kilometre Taşları

Milestones
● We published the firstenvironment policy.
2002
Milestones
● We placed first in theAccountability Ranking forTurkey.

● We signed the United NationsGlobal Compact.

● We published the first sustainability report.
2009
Milestones
● We passed the ISAE 3000independent assurance inspection(for the first time)

● Became aFounding Member of the Group ofClimate Change Leaders.

● We became Turkey’s number one food and beverages company among the CDP GlobalTransparency Leaders.

● The “2°C Communique” was signed.
2011
Milestones
● We became one of the two companies in Turkey’sCDP Carbon Performance Leaders.

● We completed the TCCC and WWF (World WildlifeFund)'s “10 Best Energy-Saving Target Program”with the Izmir and Mersin Plants in Turkey.

● We represented Turkey among the best GreenEconomy Projects at the Rio+30 Conference.
2012
Milestones
● The CCI Operation became the first multinational operation to complete the “10 Best Energy SavingTarget Program” at TCCS among all bottling companies.

● In the UNGC 100 Index, we became the first company from Turkey and under the TCCS.

● New “Ethics Rules”, “Policy on Rights and theWorkplace” and “Ethics Service” were implemented.We obtained the first ISO 14064-3 certificate for theGHD inventory.

● We ranked among the Carbon Transparency andPerformance Leaders in the CDP Turkey 100 ClimateChange Report.

● We obtained the “Gender Equality Certificate” fromKAGİDER in Turkey.
2013
Milestones
● We obtained the second highest grade in the CDP Turkey ClimateLeadership Awards in the transparency category.

● We became the first company fromTurkey to participate in the CDPGlobal Water Program.

● We raised our CorporateManagement grade from 8.8 to 9.25.
2014
Milestones
● We announced the “2025 vision and strategic framework”.

● We joined the “BIST 50 SustainabilityIndex”.

● We joined the “Euronext Vigeo Development 70 Index”.

● We signed the “BM Principles for the Empowerment of Women”.

● We raised our Corporate Management grade from 9.25 to 9.40.
2015
Milestones
● We joined the “BIST 100 Sustainability Index”.

● We joined the “MSCI Global Sustainability Index”.

● We joined the “FTSE4 Good Development Index”.

● We were listed among the “TurkeyCDP Climate Change Leaders”.
2016
Milestones
● We joined the “ECPI Developing Markets ESG Equity Index”.

● We joined the “Vigeo Eiris BestDeveloping Market Performances”ranking.

● We joined the “30% Club TurkeyBoard” initiated by Sabancı University’s Corporate ManagementForum and the Capital Markets Board within the scope of the IndependentWoman Executives Project.
2017
Milestones
● Our Corporate Management grade reached 9.45.

● An independent assurance report was obtained for the waste data of theTurkey Operation.

● The “Policy on Rights at the Workplace” was updated as the“Human Rights Policy”.

● The CCI Dudullu Headquarters obtained the LEED Gold Certificate.
2018
Milestones
● We became a member of ERTA(Integrated Reporting Turkey Network).

● We joined the “Business World Plastic Initiative” in Turkey.

● We obtained 9.46 points in Corporate Management.
2019
Milestones
● We are still the only company from Turkey and under TCCS in the UNGC100 Index.(Since 2013)

● The CORE Alliance (Collect and Recycle Alliance) was founded inPakistan.

● We signed the LEAD Network CEO Undertaking.

● We became a member of “Buyers Supporting VIVE”.
2020
2002
• İlk Çevre Politikasını yayımladık.
2009
• Türkiye Hesap Verebilirlik Sıralamasında ilk sırada yer aldık.

• Birleşmiş Milletler Küresel İlkeler Sözleşmesi'ni (UNGC) imzaladık.

• İlk Sürdürülebilirlik Raporunu yayınladık.
2011
• ISAE 3000 bağımsız güvence denetiminden geçtik (ilk kez).

• İklim Değişikliği Liderler Grubu Kurucu Üyesi olduk.

• CDP Küresel Saydamlık Liderleri'nde Türkiye'nin bir numaralı gıda ve içecek şirketi olduk.

• “2°C Tebliği” imzalandı.
2012
• Türkiye'de İzmir ve Mersin Fabrikaları ile TCCC ve WWF'nin (Dünya Doğayı Koruma Vakfı) "En İyi 10 Enerji Tasarrufu Hedefi Programı"nı tamamladık.

• Rio+20 Konferansı'nda en iyi Yeşil Ekonomi Projeleri arasında Türkiye'yi temsil ettik.

• Türkiye'nin CDP Karbon Performansı Liderleri arasında ilk iki şirketten biri olduk.
2013
• UNGC 100 Endeksi'nde Türkiye'den ve TCCS bünyesindeki ilk şirket olduk.

• Yeni "Etik Kurallar", "İşyerindeki Haklar Politikası" ve Etik Hizmeti" uygulamaya kondu.

• GHD envanteri için ilk ISO 14064-3 Sertifikasını aldık.CDP Türkiye 100 İklim Değişikliği Raporu'nda Karbon Saydamlık ve Performans Liderleri arasına girdik.

• Türkiye'de KAGİDER'den "Cinsiyet Eşitliği Sertifikası" aldık.

‍• CCI Operasyonu, tüm şişeleyiciler arasında TCCS'de "En İyi 10 Enerji Tasarrufu Hedefi Programı"nı tamamlayan ilk çok uluslu operasyon oldu.
2014
• CDP Türkiye İklim Liderliği Ödülleri saydamlık kategorisinde en yüksek ikinci puanı aldık.

• CDP Küresel Su Programı'na Türkiye'den katılan ilk şirket olduk.

• Kurumsal Yönetim Puanını 8.8'den 9.25’a çıkardık.
2015
• "2025 Vizyonunu ve Stratejik Çerçevesini" açıkladık.

• "BIST 50 Sürdürülebilirlik Endeksi'ne" katıldık.

• "Euronext Vigeo Gelişim 70 Endeksi'ne" katıldık.

• "BM Kadınların Güçlendirilmesi İlkelerini" imzaladık.

• Kurumsal Yönetim Puanını 9.25'den 9.40’a çıkardık.
2016
• "BIST 100 Sürdürülebilirlik Endeksi'ne" katıldık

• "MSCI Küresel Sürdürülebilirlik Endeksi'ne" katıldık.

• "FTSE4Good Gelişme Endeksi'ne" katıldık.

• "Türkiye CDP İklim Değişikliği Liderleri" arasında listelendik.
2017
• “ECPI Gelişmekte Olan Pazarlar ESG Özkaynak endeksine" katıldık.

• “Vigeo Eiris En İyi Gelişmekte Olan Pazar Performansları Sıralamasına" katıldık.

• Bağımsız Kadın Yöneticiler Projesi kapsamında Sabancı Üniversitesi'nin Kurumsal Yönetim Forumu ve Sermaye Piyasaları Kurulu tarafından başlatılan "%30 Kulübü Türkiye Kurulu'na" katıldık.
2018
• Kurumsal Yönetim Puanında 9,45’e ulaştık.

• Türkiye Operasyonu'nun atık verileri için bağımsız güvence raporu alındı.

• "İşyerindeki Haklar Politikası" "İnsan Hakları Politikası" olarak güncellendi.

• CCI Dudullu Genel Merkezi LEED Altın Sertifikası aldı.
2019
• ERTA (Entegre Raporlama Türkiye Ağı) üyesi olduk.

• Türkiye'de "İş Dünyası Plastik Girişimi"ne katıldık.- Kurumsal Yönetimde 9,46 puan aldık.

• UNGN 100 Endeksi'nde Türkiye'den ve TCCS bünyesinden yer alan tek şirket (2013’ten beri)
2020
• UNGC 100 Endeksi’nde Türkiye’den ve TCCS bünyesinden yer alan tek şirket (2013’ten beri)

• Pakistan’da CORE UNGC ittifakının kurucu ortakları arasında yer aldık.

• LEAD Network CEO Taahhüdü İmzalandı.

• “VIVE’ı Destekleyen Alıcılar (Buyers Supporting VIVE)” üyesi olduk.

Memberships and Cooperation

Our Memberships and Signed Initiatives

Memberships
  1. (Environmental Protection and Package Waste ReuseFoundation – Green Point)
  2. (Turkish Industry and Business Association)
  3. (Association of International Investors)
  4. (Association of Soft Beverages Producers)
  5. (Turkish Quality Association)
  6. (Foreign Economic Relations Board)
  7. (Association of Bottled Water Producers in Turkey)
  8. (Fruit Juice Industry Association)
  1. (Ethics and Reputation Association)
  2. (Investor Relations Association)
  3. (Union of Chambers and Commodity Exchanges of Turkey)
  4. (Federation of Turkish Food and Beverages IndustryAssociations)
  5. Turkey Network (United Nations Global Compact TurkeyNetwork)
  6. (Integrated Reporting Turkey Network)
  7. (Turkish Association of Corporate Management)
  8. (Global Reporting Initiative)
Signed Initiatives
  1. • The CDP Climate Change Program
  2. • The CDP Water Program
  3. • Equality at the Workplace Platform
  4. • United Nations Global Compact (UNGC)
  5. • Turkey Climate Change Platform
  6. • United Nations Women’s Empowerment Principles (UNWEP)
  1. • Brand Protection Group
  2. • 30% Club, Turkey Chapter (Growth Through Diversity)
  3. • The Business World Plastic Initiative (TÜSİAD, UNGC, SKD)
  4. • The Business World Against Domestic Violence - SabancıUniversity Corporate Management Forum
  5. • LEAD Network CEO Undertaking
  6. • Buyers Supporting VIVE
group-of-people
Recognition in Sustainability Indices
Thanks to the contributions made by our sustainable business practices, and the transparent disclosure ofour sustainability vision, CCI holds a prominent place in national and global sustainability indices.
  1. Since the initiation of the UnitedNations Global Compact (UNGC) in 2013, CCI is still the only company inTurkey to have been included in theUNGC 100 Index. The companies included in the index are chosen from among UNGC members from all around the world that meet the necessary criteria. The managements of the members meeting the necessary criteria are required to demonstrate their commitment to the 10 UNGC principles, to continuously develop and disclose their sustainability performances, and maintain a consistent fundamental profitability.
  2. Following an assessment of our sustainability practice and performance for the 2019-2020 period, CCI was included in the Borsa Istanbul (BIST)Sustainability Index in the period between December 2020 and October 2021. CCI was among the first 29 companies to be included in the BIST Sustainability Index in 2015.
  3. Following an assessment of our environment, social and corporate management performance during the 2018-2019 period by MorganStanley Capital International, CCI was included in the 2020 MSCIESG Leaders Index with a grade of BBB. In 2016, CCI was included in the MSCI Global SustainabilityIndex.
  4. In 2016, CCI was included in the FTSE4 Good Development Index due to its high performance in the are as of environmental, social and corporate governance, maintaining its position on the 2020 list. The FTSE4 Good Development Index was prepared by FTSE Russell, the global index and data leader used by investors all around the world.
  5. As of December 2017, CCI was included in the Developing MarketsESG Equity Index (ECPI). ECPI is a leading ratings and index company specialized in research relating to environmental, social and management performance.
  6. In July 2020, CCI was included once again in the Vigeo Eiris
    Best Performing Companies in Developing Markets ranking
    after being chosen as one of the100 most developed companies included in the Markets with Developing Shares consisting of 813companies from 31 countries. The companies included in this index obtain the highest scores identified through an examination based on38 criteria categorized under six main headings in the subjects of corporate environment, community and management, an assessed by Vigeo Eiris.
  7. CCI voluntarily joined the CDP Climate Change and Water Programs. CCI has been deemed worthy of the Climate Leadership Award on three occasions by CDP Turkey in the categories of performance and transparency. In2020, CCI maintained its Water and Climate Change Program score atB.
  8. The Business World AgainstDomestic Violence Project is conducted by the Sabancı University Corporate Management Forum in cooperation with TÜSİAD, together with the United Nations Population Fund (UNFPA) and the Sabancı Foundation, which are its main sponsors. Three representatives from CCI attended the BADV training within the scope of the project aimed at establishing support mechanisms at workplaces for employees who are victims of violence in their close relationships. CCI’s target is to share its management and organization capacities to promote best practices, tools and methods to reduce domestic violence in the business world. The CCI Executive Committee and the Turkey Leaders Team attended gender equality awareness training in December.
Sustainability Partners
  1. CCI is a member of the Turkish Industry and Business Association(TÜSİAD), and CCI’s CorporateAffairs Director is a member of the UNGC Turkey Board of Directors. In line with our determination concerning Sustainable Development Goals, we at CCI play an active role in the task groups formed by TÜSİAD, UNGC and SDG (SustainableDevelopment Goals) on ClimateChange, Diversity and Inclusion, and Gender Equality and Women’sEmpowerment, as well as the“Young SDG Innovators Program”and the “Business World PlasticsInitiative”.
  2. Under the Young SustainableDevelopment Goals (SDG)Innovators Program, we aim to collaborate with the best talents in the company not only in advancing sustainability efforts, but also with respect to supporting innovation and offering concrete solutions with a potential market value for their companies.
  3. CCI responded to the call made by the Turkish Industry and BusinessAssociation, the SustainableDevelopment Business Council of Turkey, and the United NationsGlobal Compact Turkey in the fight against plastics pollution through the “Business World PlasticsInitiative”. Signing the declaration of undertakings, CCI became one of the 26 pioneering companies in the initiative, demonstrating its commitment to efforts to reduce the use of plastic by 2021 and to sharing the results with the public.
  4. CCI is a founding member of ÇEVKO, and the CCI CorporateRelations Manager is a Board member. Thanks to our strategic collaboration with ÇEVKO, we have continuously increased our rate of collecting post-consumer package waste and have raised consumers’ awareness on recycling.
  5. The empowerment of women holds an important place in CCI’s sustainability strategy. Coca-Cola Turkey cooperated with theHabitat Association for the “MySister Project”. The objective of the project is to empower women by equipping them with the necessary knowledge and experience whereby they can play an active role in regional economic development, improve their economic and social standing, and participate in the economy.
  6. CCI invests in community projects related to combatting waste pollution and recovery. There cycling program launched inTurkey’s Mediterranean Region in cooperation with the UNDP has continued since 2018 with the target of increasing the waste management capacity for recycling. In 2020, CCI partnered with the UNDP to establish the CORE:Collect and Recycle Alliance in Pakistan.
  7. The priority of the Project for Technical Support for Increasing Social Dialogue in Work Life conducted by the ILO Turkey Office is to increase the capacity of social business partners and concerned public agencies, and to raise awareness of social dialogue at all levels through a holistic approach. CCI contributed to the project along with other fast-moving consumer goods companies.
  8. The CCI Corporate Relations Manager was appointed Chairman of the Board of MEDER, which was established in 1994 to support the growth of the beverages sector, increase the sector’s contribution to the Turkish economy, and lead sustainability efforts in the sector.
  9. We provided the Turkish Red Crescent with support worth TL 10 million through the Coca-Cola Foundation and conducted a support program together with the Turkish Red Crescent with in the scope of the fight against Covid-19.
  10. Product and services support was provided to 5,000 SMEs that were adversely impacted by Covid-19 through the online platform www.kucukisletmemicin.com, which was established by Metro Turkey and Coca-Cola Turkey, both major partners in the “For My SmallBusiness” campaign.
  11. İmeceLAB is an open social innovation laboratory where youths can gain competences regarding social issues, and collectively generate solutions in light of Sustainable DevelopmentGoals. CCI will organize an innovation that is open to university studentsin cooperation with İmeceLAB under the heading “SustainableConsumption and Production”,which is the 12th SDG (SustainableDevelopment Goal).
  12. As part of our efforts in diversity and inclusion, we took part in the EMBARK initiative that is supported by the EuropeanBank for Reconstruction andDevelopment (EBRD). With in the scope of EMBARK, which isa “reverse mentoring” program, we come together with talentedSyrian, Turkish and immigrant youths.
Sustainability Reporting
CCI’s sustainability report is our key communication tool for sharing our sustainability performance with our stakeholders in striving towards our target of making CCI a leader of sustainability, accountability and transparency. As our sustainability reports developed, we have been included in global sustainability indices, developed positive relations with stakeholder groups that appreciate transparency in environmental and social matters, and enhanced our corporate reputation.
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Since 2017, CCI’s sustainability reports have been assessed by the Association for SustainableDevelopment (ASD) Turkey within the framework of the World Business Council forSustainable Development (WBCSD)'s “ReportingMatters” program. The sustainability reports of member companies are analyzed based on 18 comprehensive indicators under three main categories consisting of principles, contents and experience within the scope of the program.CCI Sustainability Reports are considered good practices in the Balanced Content category, and emphasize our success in the transparent communication of these successes and areas of development. Since 2016, CCI has increased its reporting score 19 times.
Integrated Governance
The CCI Board of Directors considers sustainability a part of its business strategy and adopts the approach of creating value for all stakeholders. Developing the integrated thinking system with the transition to integrated reporting, it focuses on utilizing its financial, natural, relational, produced, human and intellectual resources in the most efficient manner in all its activities, and on continuously improving its influence on the six main areas of value-creation. To this end, the inputs and resources within the scope of each component of capital, activities conducted in keeping with the required output, and the value consequently generated for each stakeholder group are reviewed regularly and updated in accordance with needs. CCI aims at continuously carrying forward the holistic approach it has developed in assessing risks and opportunities, developing strategies, and identifying short-, medium- and long-term targets for the future.
CCI’s strong corporate management structure plays a vital role in attaining our strategic targets. The Corporate Management Committee has ultimate responsibility in identifying and implementing business strategy with aneye to the priorities of sustainability. This responsibility is assumed by theCCI Executive Committee, which is composed of senior management representatives and chaired by the CEO. In order to attain the identified targets in each of the strategic areas, the Environmental and SocialSustainability Committee, the Occupational Health and Safety Committee, the Diversity and Inclusion Advisory Committee, the Ethics and ComplianceCommittee, the Risk Committee, and the Information Security SteeringCommittee conduct separate activities with the concerned task groups within the framework of the six components of capital under an integrated thought system, issue group-level resolutions, and report to the Executive Committee.
These committees convene regularly during the year, and additional meetings are held whenever the need arises. The InvestmentCommittee, consisting of the CEO, the COO, the Financial Affairs Director, and the Group Supply Chain Director, meets whenever necessary before important investment decisions are made. The CIO, too, attends InvestmentCommittee meetings before decisions on investments related to digital technology are made.
CCI conducts all its operations in accordance with the accepted arrangements in the countries in which it operates, and with CorporateManagement Principles supervised by the Turkish Capital Markets Board.Every year, we publish our Corporate Management Principles ComplianceReport to provide our stakeholders with transparent information on our performance. Corporate Management performance is managed by the CCIBoard of Directors in cooperation with the Corporate Management and the Audit and Early Detection of Risk Committees within the body of theBoard of Directors. The Corporate Management Committee assumes the responsibilities of the Nomination and Compensation Committees.
For information on the committees, please click on the following link
Coca-cola-turkey-office
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Risk Management
The Structure of Risk Management
While risk management is overseen by the RiskIdentification Committee that works under the Board of Directors, the Enterprise Risk Management(ERM) Team works directly under the CEO and theCommittee for the Early Detection of Risk and playsa facilitating role. It is also responsible for carrying out risk assessments. The members of the ERM team are the CEO, Strategy and Business DevelopmentDirector, and Regional Directors.

Using inputs from the World Economic Forum, global questionnaires and the Coca-Cola System, the ERM conducts country- and group-level risk assessments.Risks are prioritized according to their general likelihood of occurrence, their possibility of occurring in the short run, and their potential impact.
CCI Country General Managers are responsible for risk management and mitigation. Country GeneralManagers identify priority threats and improvement opportunities according to the results of risk assessments, integrate these into Strategic BusinessPlans, and prepare risk mitigation action plans.High-priority risks are communicated to the Board of Directors Committee for the Early Detection of Risk. The results of internal inspections carried out to monitor risk mitigating plans are communicated to the Audit Committee.
Risk Management Training
We provide our employees with regular training on risk management and supply information on theERM website accessible over the CCI internal portal. Along with an ERM tool, the website includes guides, essential articles, useful links, and an awareness-raising training presentation pertaining to ERM.
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Business Continuity
CCI implements the Incident Management and Crisis Resolution (IMCR)program prepared by TCCC for the purpose of creating and maintaining an efficient and integrated structure for preventing and managing incidents.The implementation of the IMCR program is a fundamental management activity, and everyone at CCI is responsible for implementing this program.We have incident management teams in all countries of operation to prevent or mitigate the impact of incidents on our operations. Each team attends annual training meetings, at which they work on complex incident simulations. Within the scope of the IMCR program, each country conducts the IMCR Verification Program once every three years to prepare for crisis situations, raise awareness, identify shortcomings, and develop action plans for improvements.
The IMCR Verification Program was conducted inAzerbaijan, Kazakhstan, Kyrgyzstan and Pakistan in 2019. We trained crisisteams in Jordan and Iraq in 2020 and completed the verification program.Crisis management teams became part of our way of conducting our dailybusiness during the Covid-19 pandemic. In addition to prioritizing employees’health and safety, we took each managerial step carefully and diligentlywithin the framework of pandemic conditions to maintain our productionand distribution operations without interruption within the framework of ourresponsibility towards the community.
Data Security and Confidentiality
According to the WEF Global Risk Report, data fraud or theft, cyber-attacks, and the collapse of information infrastructure are among the top-10 global risks in terms of their likelihood and potential impact. At the same time, according to a Post-Covid-19 Challenges and Opportunities Report published by the WEF, the increase in global online communication, together with the Covid-19 pandemic, has the potential to bring with it important cyber-security problems. To address these challenges and mitigate the risks, CCI has a strong data security and confidentiality program with the following basic elements to secure its own information assets.
Information Security Management
CCI implements a company-wide information security management structure that ensures the effective management of potential risks and includes security and confidentiality checks of our information systems and services. The Information Security Steering Committee, consisting of the Executive Committee and the security management team, has been acting as a management organ since 2009. In order to attain its security targets, CCI implements a comprehensive Information Security Management System (ISMS) in accordance with the ISO 27001 ISMS standard. CCI obtained its ISO 27001 certificate in 2016 and has completed its security inspection every year since 2016, including 2020.
Security Awareness
Since 2014, CCI has implemented a mandatory cyber-security awareness program for all its employees, by which it supports cyber-security awareness throughout the company. Reports of the awareness program are submitted to senior management to inform them of risks. This awareness program includes online and offline training, awareness-raising posters placed in announcement areas at CCI workplaces and corporate social network groups, and email notifications on various topics, such as phishing, travel security, URL security, email security and physical security. Also, cyber-security competitions in which prizes are given to the most active employees are organized.
Confidentiality and Protection of Data
CCI takes precautionary measures to ensure the security of the personal information of its employees and customers. Our BT environment, security measures, policies, and cyber-security awareness program promote compliance with confidentiality and data-protection requirements. CCI has achieved compliance with legislation by meeting legal requirements on the Protection of Personal Data in Turkey, and is registered with the VERBİS system. In order to keep up with new regulatory developments and maintain general compliance, the Data Protection and Digital Confidentiality Committee meets regularly and conducts spot checks for the purpose of maintaining data protection awareness, communicating the results of these spot checks to senior management.
Regulatory Compliance
CCI has designed and implemented numerous initiatives to ensure compliance with the following regulatory requirements:

Law No. 6698 on the Protection of Personal Data (KVKK) and resolutions issued by the Personal Data Protection Board
Communiques issued by the Capital Market Board
Compliance with the Regulation on Commercial Communication and Commercial Electronic Messages under the Law on
the Regulation of Electronic Commerce, and meeting the requirement to register with the Message Management System
Authorized Economic Operator program under the Ministry of Customs and Trade
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Ethics Management
At CCI, our fundamental values are accountability and integrity. We are obligated to protect the Coca-Cola brand, which is our most valuable asset, and CCI, to the best of our ability. CCI Ethics Rules guide our employees in observing our values and “doing what is right”. These rules apply in all the countries in which we operate. Also, CCI has developed mechanisms to help our stakeholders report any practices carried out within the body of the company that may be unethical or contrary to legal regulations to the CCI Ethics and Compliance Officer, or through an independently operated ethics hotline.
Ethics Governance
CCI’s Corporate Management Committee ensures that Ethics Rules are fully implemented and practiced. Implementation of the rules remains within the scope of the duties of the CCI Ethics and Compliance Manager and the Local Ethics and Compliance Directors. The CCI Ethics and Compliance Committee consists of the CFO, the Human Resources Director, the Chief Legal Counsel, the Corporate Relations Director, and the Internal Audit Director.

The CCI Ethics and Compliance Manager keeps a record of all non- compliance incidents within CCI and ensures the follow-up and completion of investigative processes. Investigations relating to violations of Ethics Rules are generally managed by the CCI Internal Audit Department, while in situations concerning violations of Human Rights Policy, investigations are conducted by the Human Resources Department and the CCI Ethics and Compliance Committee issues decisions according to the findings of investigations. The power to make decisions in these categories may be delegated to Local Ethics and Compliance Committees as per the Manual on the Management of Ethics Rules-Related Matters.
As a consequence of each infraction of Ethics Rules, disciplinary action is taken in keeping with the nature and circumstances of the infraction, and in line with the legislation of each country. While a letter of warning is sent with respect to first-time and less important violations, employment contracts may be suspended without pay, progress payments and premiums may be lost, and the employment contract may be terminated in the event of more serious violations.
For information on the Management of Bribery and Corruption, please see “Chapter 6-Additional Remarks Regarding the BIST”.
CCI Ethics Service
Operated by a fully independent third party, it is accessible 24/7.
It can be accessed via the website www.cciethicsline.com (Turkish, English, Russian and Arabic), or via a special telephone number.
Online translation services are available in Arabic, English, Russian and Turkish, being the languages that a large majority of our employees speak. Notifications are also received in other languages, and are recorded after being translated by us.
If the complainant so chooses, the employee’s name and email addressshall remain anonymous and confidential.
Face-to-face Notification
Employees may report their concerns directly;

to their Managers
to the Local Ethics and Compliance Directors.

The name and information of the employee shall remain confidential if the complainant so chooses.
Work we have put into practice in 2020
In 2020, we conducted new work on our policies pertaining to relations with third-party stakeholders, gifts and hosting, and conflicts of interest. Our objective for 2021 is to ensure the implementation of these updated policies, and to ensure unity in their application in all the countries in which we operate.

Additionally, in cooperation with the EBRD, we have continued with the“Ethics Risks Management Program” to reduce third-party risks related to CCI distributors. The second phase of the ethics and compliance management program for beneficiary distributors was completed before the emergence of the Covid-19 pandemic.
We aim to complete the program in 2021, and to develop the initiative to include a certificate program to ensure the operational continuity of the enterprises.

As a result of complaints it received with respect to the carbonated drinks market, of which we are the leader this year, the Turkish Competition Board launched an investigation to determine whether a violation of Law No. 4054 on the Protection of Competition had occurred. As is known, the launch of an investigation by the Competition Board does not necessarily mean that a violation of competition has occurred. All the initiatives that CCI carries out in full compliance with the rules of competition legislation are shared openly during the investigative process.
Ethics Training
In 2020, we attained our 2019 target by bringing EtikTV on air to allow all our employees to obtain integrated knowledge of Ethics Rules. Consisting of five different sections covering all subjects related to Ethics Rules, and reaching all CCI employees to explain these subjects with case analyses, EtikTV represents the first online Ethics Training platform. We prepared EtikTV in 11 languages such that Ethics Rules can be mastered in the languages of the countries in which we operate. We had achieved a completion rate of almost 100% by the end of 2020. Also, EtikTV is now part of the orientation program and newly-recruited employees are now able to perform their duties with an awareness of CCI Ethics Rules from day one.
In early 2020, we provided Ethics Rules training to 1,231 CCI employees, through 28 separate classroom sessions, in our Turkish operation alone. Using digital boards and the intra-company social media platform in all the countries in which we operate, we raised awareness by continuing to provide training on Ethics Rules, and rules on combatting bribery, to employees. We continued to review and update Ethics Rules and policies in the fight against bribery in line with TCCC practices.
Raising Awareness on Ethics
Employees have been provided with training related to the revised Ethics Rules, the Ethics Rules Manual, and the provisions of procedure since 2013. The Ethics Rules Manual and all related procedures are shared with our employees. All newly recruited employees are obliged to sign a form acknowledging that they have read the Ethics Rules and have agreed
to comply with their provisions. All employees are expected to state this acknowledgment. Representatives and consultants hired by CCI and by third parties working on behalf of CCI may obtain copies of the Rules to understand their obligations.
CCI Ethics Risks Management Program
The IRM that was implemented in 2019 focuses on supporting the SMEs in CCI’s supply chain to ensure that CCI distributors observe internationally accepted practices and develop their corporate management skills. The program supports SMEs in becoming more integrated into the CCI supply chain, observing internationally accepted practices, preparing compliance programs, holding training and awareness programs related to Ethics Rules, and complying with CCI’s Ethics Rules. CCI plans to extend the scope of the program within the next term so that a greater number of distributors may benefit from it.
Stakeholder Engagement
Establishing effective and strong dialogue with stakeholders is important for rendering our operations sustainable and including our stakeholders in our sustainability strategy. Since 2013, we have implemented a comprehensive stakeholder mapping effort under AccountAbility’s AA1000 SES Standard and the EFQM Company Perfection Model to prioritize our stakeholders and our means of communication.
By regularly including each stakeholder group in the processes, we aim to share our work on sustainability, evaluate material issues, and consolidate shareholders’ ideas and feedback. The various means of communication with different stakeholder groups, and how we respond to their questions and concerns, are demonstrated in the following tables.
Stakeholder Day Series
The CCI and TCCC Stakeholder Day Series was designed as a local loyalty platform to create awareness on our sustainability efforts and our production capacity in the countries in which we operate, and to further improve our relations with key local stakeholders.

The Stakeholder Day Series has been systematically implemented since 2017; CCI and TCCC representatives come together with local stakeholders to provide information on operations in the region, CSR work, and CCI’s sustainability vision. Stakeholder Days planned to be held in Bursa, Isparta and Köyceğiz in 2020 were postponed to 2021 due to the Covid-19 pandemic.
TCCC Reputation Questionnaire
Within the body of the TCCC, we plan and implement our actions based on our stakeholders’ opinions and feedback. Therefore, we assign greater value to our stakeholders’ opinions, and periodically distribute corporate reputation questionnaires to our internal and external stakeholders.

In 2019, we distributed a reputation questionnaire among a sample group representing the urban population of Turkey in line with EFQM and AA1000 standards through a third-party corporation. Through this questionnaire, we aimed to examine our consumers’ thoughts and attitudes towards Coca-Cola Turkey on issues such as transparency, accountability, financial resilience, corporate social responsibility, product and services quality, work conditions, campaigns/ advertisements, communication, innovation, the environment, and company performance.
Platforms for Communication with Key Stakeholders
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Prominent Stakeholder Inclusion Practices of 2020
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Materiality Analysis
Materiality analysis is a continuous process for us and is important for reviewing our progress and annually assessing its results. Within the scope of this analysis, we contact each stakeholder group regularly to consider and prioritize their opinions and feedback.
We analyze priority issues under four major headings, namely;
Global and sectoral risks and opportunities,
CCI and the TCCC’s strategic priorities,
CCI’s operations and the social, economic and environmental impact on the value chain,
The concerns and expectations of stakeholders.
Our up-to-date materiality matrix, which we created based on our studies and analyses, has been evaluated and approved by senior management.
In 2020, we held meetings with our external stakeholders in Turkey, Pakistan and Kazakhstan on the targets and commitments we identified for 2030, on which we received their opinions and feedback. During this reporting period, topics whose impact on our stakeholders’ evaluation and decision processes, and whose scope of impact for CCI increased in parallel to changing and transforming conditions in the world became priority issues. We reviewed
the topics that were included in our targets and commitments for 2030, and conducted an online questionnaire related to priority topics that would form the scope of our Integrated Annual Report at the end of 2020, together with our report consultant.
After the questionnaires were completed, we analyzed the results to form a list of priority issues. We categorized important topics as priority, high-priority and very high-priority in our studies and analyses and entered these topics in the matrix in order of percentage distribution regarding their priority for key stakeholders and CCI.
CCI 2020 Prioritization Matrix
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Material Sustainability Topics Of 2020
Consumer Health ; we offer our consumers a wide-ranging portfolio of beverages that is consistent with their choices and is of high product quality and safety standards, which is vital in our business model.
Customer Value ; we are determined to continuously increase the level of customer satisfaction across our countries to achieve operational perfection with our customer-oriented business model and our superior supplier management approach.
Human Rights ; through our pioneering policies and practices we are committed to becoming a workplace that is perfect, safe, and that fosters diversity, offers equal opportunities, and that has a positive effect on our employees, and on all employees across our operational value chain.
Human Capital ; we listen to our employees’ expectations on various interaction platforms, aim at creating a workplace that fully meets their expectations, and invest in their development through talent development programs.
Through Social Development ; we are committed to becoming a responsible corporate citizen that proudly serves the community with our projects that focus on the employment of young people, the empowerment of women, water management, and zero-waste, and that are supported by employee volunteerism, and to make a positive economic impact through our investments.
Environmental Footprint ; we aim at minimizing our impact on the environment by using fewer natural resources, carrying out efficient operations, generating less waste, and by intensely focusing on “energy management and climate change”, “water” and “sustainable packaging” practices.
CCI At A Glance