Compliance Case Study Code of Business Conduct & Ethics

AB InBev AB InBev launches an interactive Code of Business Conduct & Ethics e-learning programme with Interactive Dialogues

Anheuser-Busch InBev is the leading

ML: What was the main reason for rolling

global brewer and one of the world’s

out this on-line training programme on

top five consumer products companies.

Business Conduct & Ethics? Has it ever

With a dream to become ‘The Best Beer

been done before within the AB InBev

Company in a Better World’, the company

Group?

has a strong, balanced portfolio. With four of the top ten selling beers in the

KS: This is the third consecutive year that

world, Anheuser-Busch InBev holds

we have rolled out the Code of Business

either the No. 1 or No. 2 position in 19

Conduct training within the AB InBev group.

key markets. Headquartered in Leuven,

The aim is to raise awareness on the topics

you avoid “you shall not do this, and you

Belgium, Anheuser-Busch InBev leverages

covered by the CoBC and to emphasise

shall not do that”;

the collective strength of approximately

how our company relies on every individual’s

a picture can tell a thousand words.

116,000 people based in operations in 23

commitment to

countries across the world.

compliance. Each participant must complete

ML: The programme also contains a

an annual certification of the knowledge of the

quiz section. The participant starts off

Code.

with 100 credits and has to maintain 80

ML: Marianne Leijs, Marketing Coordinator at

credits to pass the course. What were

Interactive Dialogues NV KS: M s Kylie Sturtz, Legal Director of Compliance & Competition at AB InBev

ML: The programme features a lot of

the reactions to this unique approach?

drawings from the Belgian cartoonist Ludo Goderis. Were these of great value

KS: The number of reactions was amazing;

in order to make the programme lighter

people became very competitive. The

and more fun?

“countdown formula” has obviously a much bigger effect on people than a building-up

KS: Indeed, the great value of using cartoons

formula. The participants wanted to keep the

is: it is fun, but you still make a clear point

initial 100% and every incorrect answer meant that they really concentrated on getting the

without pointing the finger or adopting an

rest of the questions right. Definitely something

accusatory tone;

to repeat!

www.interactivedialogues.com

ML: Have any other initiatives, besides this programme, been taken in the past to enhance business conducts & ethics within the company?

KS: All new joiners are introduced to the Code of Business Conduct on the welcoming days, and two years ago we organised a poster campaign in offices to raise awareness. From time to time,

About Us Interactive Dialogues was founded in 1998

If you would like more information about

and serves a growing number of national

our services, please visit our website:

and multinational companies.

www.interactivedialogues.com

Our sales, application development and administration teams are based in Brussels,

For general or sales enquiries:

Belgium and Cheshire, UK.

sales@interactivedialogues.com

“Compliance” email news flashes are sent throughout AB InBev, e.g. when compliance guidelines are created or updated.

KS: The training is mandatory for senior

ML: What were your initial expectations

The main initiative remains the annual

management around the world, about 3.000

regarding this project? What was the

e-training programme, which is announced in

people globally. That is the minimum required

main goal you were looking to achieve?

the Company News Flashes via a message

audience. However, each operational Zone

from the Chief Legal Officer.

(Western Europe, Asia Pacific, North America,

KS: The initial expectation was to raise

Latin America South and Latin America North)

awareness of the Code of Business Conduct.

can decide to include additional personnel,

As in many other international companies,

according to its habits and needs in that

within AB InBev there are several different

region.

sub-entities with their own Code and

As a result, in 2009 the training was in

guidelines. So, on the one hand, we wanted

fact sent out to about 14.000 AB InBev

to increase compliance with the company’s

employees.

guidelines (sometimes local guidelines), and

The training will also be available year round

on the other hand bring a consistent global

for new joiners.

compliance message to the whole AB InBev group. In the end, we created one global

ML: Who within AB InBev took on the

ML: In how many languages was

training programme, with links to specific local

responsibility to roll out and design this

the programme set up? Were these

content sites where this was needed. On

programme?

languages necessary to encourage

some sites, we also used local brand logos

people to take part in the programme?

and branding to give it the right look and feel.

KS: AB InBev’s Audit Committee oversees all our compliance work, including the roll-out of

KS: The programme is available in eight

the Code of Business Conduct training. On

languages. It is indeed necessary to

the ground, the Corporate Compliance team

encourage people to follow the course as

organises the roll-out and design of the global

we have operations across a wide range of

programme in cooperation with the Zone

countries, but it is also a legal requirement in

legal teams.

some countries to have the training available in the local language. The availability in local

ML: Who and how large is the target

language allows us to broaden the scope to

audience? How did you define that

cover employees who may not be fluent in

audience?

English.

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ML: What was your experience of working with Interactive Dialogues? How was the technical and general support?

KS: The main reasons why we have chosen to work with Interactive Dialogues, and will continue to work with them, are: lexibility: The content as well as the F structure of our training has been built up step-by-step in close cooperation with the account manager reativity: in the lay-out (cartoons, logos), in C finding technical solutions User-friendly administration tool ML: What were the first reactions after

ML: Will the programme be repeated next

KS: Two things:

year?

1. “Enlighten” the training with humour and

KS: Yes, definitely.

2. Bring a global message, while respecting

launching the project?

engage your audience.

KS: Apart from some initial technical issues

the local tweaking by using local logos and

related to internet access, which were

incorporating local guidelines.

mainly due to our own network, the overall comments were positive. The fact that we

ML: What would you do differently next

used humour to convey some serious content

time?

has been much appreciated.

The few critical comments that we received

KS: In the US, additional ethical

were mainly about the substantive content

questionnaires are sent out on an annual

of the questions (particularly triggered by

basis. We will now look how to incorporate

the notorious “countdown” in the individual

them in the single ethical platform.

testing). Some people felt a few questions were not that clear but within ethics it isn’t all

ML: Do new employees have to take this

black and white, is it?

on-line course as well?

KS: Yes, the training will also be available year round for new joiners.

ML: What advice could you give other companies that are planning similar ethics programmes?

Contact us: T: +32 (0)2 713 6300 E: sales@interactivedialogues.com W: www.interactivedialogues.com W: www.idoxgroup.com

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