This policy emphasizes PepsiCo’s obligation to act ethically and responsibly in all business dealings by providing a clear framework that: 

• Prohibits both public sector and commercial bribery. 
• Addresses required anti-corruption due diligence processes to be conducted on third parties. 
• Explains the rules that must be followed regarding gifts, meals, travel and entertainment relating to Government Officials. 
• Outlines requirements for donations, sponsorships and corporate social responsibility (CSR) activities with a government touchpoint. 
• Emphasizes the importance of maintaining accurate books and records for all PepsiCo transactions. 

The provisions within this policy apply, where appropriate, to all third parties who are bound by PepsiCo’s Supplier Code of Conduct. 

To learn more about this policy and how PepsiCo promotes Acting with Integrity download a copy of our Global Anti-Bribery Compliance Policy. 

If you suspect a possible violation of our Code, it is your responsibility to Speak Up and report it.

Voicing Your Opinion Fearlessly through Speak Up does more than address a single issue; it often leads to positive organizational changes and a better work environment, including training, policy revision and process enhancements.

Reports may be made online or by phone to dedicated phone lines in countries throughout the world. The same protections of confidentiality and, where permitted, anonymity are provided through our telephone lines and webline.