Training-Contact-Action – Making Compliance and Integrity Part of Our Culture
We have dedicated compliance and integrity staff and five regional compliance officers around the world who work with senior management to implement our program. Our compliance and integrity team helps to ensure that our employees know what is expected of them and how to make the right decisions, especially when faced with difficult situations. Our in-person and online training programs help employees understand legal and ethical business practices.
Speaking Up and Being Heard
We expect employees to ask questions and raise concerns about business practices when they see something they think might be wrong. There may be times when employees are not comfortable speaking with their supervisors, compliance officers or human resources contacts, or simply wish to remain anonymous. Consistent with applicable local law, we have implemented a toll-free telephone HelpLine (PDF) and are implementing an email version as well, so that our employees can confidentially and, if they wish, anonymously report instances of suspected wrongdoing or ask questions about compliance matters. Our HelpLine (PDF) operates in more than 60 countries.
Listening, Investigating, Acting
In 2008, our compliance and integrity group received approximately 1,500 contacts from around the world through our "Speaking Up" channels. Many of these contacts were questions about our compliance policies and program or matters that we referred to other departments for handling. Last year, we received nearly 600 reports of misconduct that required investigation. Some of these matters resulted in disciplinary action, including the separation of 78 people from the company.
Report to Management and the Board
To ensure that senior management and the Board of Directors are aware of any potentially significant matters, our compliance and integrity group reports investigation to members of our executive team and the Audit Committee of the Board of Directors.
External Reports of Wrongdoing
Reports from people outside of company of suspected wrongdoing may also be brought to our attention in three ways:
By mail:
Compliance & Integrity Department
Kraft Foods Inc.
Three Lakes Drive
Northfield, IL 60093
USA
By e-mail:
Through our Integrity HotLine: Our Integrity HotLine is a toll-free service operated for Kraft Foods by a third-party. The HelpLine is accessible 24 hours a day, every day, and language interpreters are available. View a listing of toll-free numbers by country (PDF).