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OUR INTEGRATED
GOVERNANCE APPROACH

CCI Board of Directors considers sustainability as an integral part of its business strategy, and aligns its approach with creating value for all stakeholders. The company is focused on making use of its financial, natural, relational, manufactured, human and intellectual resources in the most efficient way, thereby continuously improving its impact. In order to achieve this goal, the company regularly reviews the inputs and resources for each capital factor as well as all activities performed in accordance with the desired output and the value created for each group of stakeholders as a result of these activities, and updates them in line with any requirements. CCI aims to continuously improve its holistic approach to assessing risks and opportunities, developing strategies, and identifying short, medium and long-term goals for the future.

In all corporate activities, CCI is committed to comply with the applicable local regulations as well as the Corporate Governance Principles supervised by the Capital Markets Board of Turkey. We publish a Corporate Governance Compliance Report each year to communicate transparent performance information to our stakeholders. Performance of the Corporate Governance is managed by CCI Board of Directors in cooperation with Corporate Committees under Board of Directors. The duties of the Nomination and Remuneration Committee are also performed by the Corporate Governance Committee.
CCI’s strong corporate governance structure plays a vital role in achieving our strategic objectives. The Corporate Governance Committee has the ultimate responsibility in identifying and implementing the business strategy by taking sustainability priorities into account. This responsibility is assumed by CCI’s Executive Committee, which is comprised of a representative from senior management and steered by the CEO. Under the sponsorship of the CEO, general sustainability topics are led by CCI Group’s Sustainability Office. The Group Corporate Affairs Director, the Group Supply Chain Director, COO and country general managers act as sponsors for environmental sustainability topics. Separate task forces work in an integrated framework for 3 main focus areas: Climate Change, Water Leadership, and Sustainable Packaging & Waste Management. Transformation programs that we plan to adopt in our offices and the “Hand in Hand Environment Program” implemented in our production facilities act as complementary elements. A meeting is held by task forces 2-4 times a month, involving any relevant functions. They report to the Steering Committee on a quarterly basis.
When it comes to Social Sustainability, the Group HR Director acts as a sponsor. The Occupational Health and Safety Steering Committee and the Diversity and Inclusion Advisory Board are also involved. Location-based OHScommittees meet every month and report to the Country Health and Safety committees on a quarterly basis. In cooperation with Country Committees across the entire CCI geography, the Group OHS team coordinates OHS-related issues and reports to the Occupational Health and Safety Steering Committee, which meets every six months. The Diversity and Inclusion Advisory Board focuses on 3 key areas: Gender Equality, Intergenerational Diversity, and Culture and Experience.
On the governance side, Investment Committee, Risk Committee, Ethics and Compliance Committee, Information Security Steering Committee and Business Continuity Committee work separately in close connection with the relevant working groups around 6 capital factors through an integrated framework in order to achieve the objectives specified for each of the identified strategic issues, making group-level decisions and reporting to the Executive Committee. These committees convene at regular intervals throughout the year, as well as in a cases of urgency. Comprised of the CEO, COO, Chief Financial Officer and  Group Supply Chain Director, the Investment Committee meets as deemed necessary prior to important investment decisions. In case of investment decisions on digital technology, the CIO also attends the meetings hold by the Investment Committee.

Our Integrated Governance Model

Board of Directors
Sustainability
Committee
Corporate Governance Committee
Audit Committee
Early Risk Detection
Committee
Sustainability Office
Environment
Social
Governance
Climate Task Force
Water Task Force
Sustainable Packagingand Waste Management Task Force
Diversity and Inclusion
Human Rights
Health and Safety Committee
Investment Committee
Risk
Ethics and Compliance
Information Security
Business Continuity Management
Green Office Initiative
Hand in Hand Environment Program
Community Development

Risk Management

Risk Management Governance Structure

The risk management is governed by Early Risk Detection Committee reporting to the Board. Enterprise Risk Management (ERM) Team, also reports directly to the CEO and the Early Risk Detection Committee and acts as the facilitator. ERM is also in charge of conducting risk assessments. ERM team members are the CEO, the Treasury and Investor Relations Director and the Regional Directors.

ERM conducts risk assessment on country and group levels using the input from the World Economic Forum, global surveys and The Coca-Cola System. The risks are prioritized based on their general likelihood, and the probability of occurrence in the short term and impact.
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Country General Managers of CCI are responsible for risk management and mitigation. They identify the prioritized threats and opportunities based on the risk assessment results, integrate them into their Strategic Business Plans and prepare the mitigation action plans. High-priority risks are reported to the Board’s Risk Detection Committee. The results of the internal audits performed to track the risk mitigation plans are reported to the Audit Committee.
Board of Directors
Corporate Governance
Committee
Audit Committee
Early Risk Detection Committee
Country General Managers
Risk Mitigation Action Plans
Risk Management Trainings
CCI employees are regularly trained on risk management and informed via the ERM website that is accessible through the CCI internal portal. The website provides an ERM tool along with guidelines, leading articles, useful links and an awareness training presentation on ERM.
Board of Directors
Corporate Governance
Committee
Audit Committee
Early Risk Detection Committee
Country General Managers
Risk Mitigation Action Plans

Business Continuity

CCI implements TCCC’s Incident Management and Crisis Resolution (IMCR) program, which is designed to create and maintain an efficient, integrated structure for preventing and managing incidents. Implementation of the IMCR program is a key management activity and is everyone’s responsibility at CCI.

To ensure that we prevent or reduce the impact of incidents on our business, we have incident management teams in all countries of operation. Each team joins our annual training sessions, and collectively work on simulations of complex incidents. As part of the IMCR program, each country conducts the IMCR Validation Program every three years, which aims to create readiness for crisis situations, build awareness, identify gaps and develop action plans for improvements.

The Incident Management and Crisis Resolution (IMCR) program within the CCI operation is managed by IMCR Country Coordinators together with the Group IMCR Group Coordinator. Additionally, there are two key teams responsible for the IMCR program:

1. Incident Analysis Team (IAT)
2. Incident Management Team (IMT)
The Incident Management Team-Roleand Responsibilities
In addition, there are two key teams responsible for the IMCR program – the Incident Analysis Team (IAT) and the Incident Management Team. The IAT comprises permanent members and meets regularly. The Incident Management Team is assembled to deal with a specific situation (incident, serious incident or crisis) once it has been identified by the IAT. Both the IAT and Incident Management Teams are joint TCCC/CCI teams.

For the incidents that happen in group level (incidents that include more than one CCI countries) Minutes meetings should be prepared immediately following the meeting and presented to CEO of CCI, with copies also being sent to the CCI IMCR Core Team.
The Incident Management Team Function
The Incident Management Team(IMT) consists of “expert” members co-opted by the IAT to assist in the management of a specific incident. Expert members are function heads or their representatives (External Affairs, Technical, Operations, Finance, HR, Marketing, IS, Distribution, Security, Planning, etc.) from either TCCC or local bottling partner that are not already on the IAT. The IMT can also include other key specialists either internal or external to the Coca-Cola system, whose expertise may be required from time to time depending upon the nature of the incident. They should be prepared to provide the IMT with expert advice and should be familiar with the IMCR process and plan.

The IMT does not generally include the COO’s from CCI or the Region General Managers from TCCC. During an incident, it is important to maintain business operations and have these senior managers focus on an incident may not be in the best interests of the business. These senior managers are provided regular briefings and recommendations for action and their decisions are implemented by the IMT.
Our work
In 2019, we conducted the IMCR Validation Program in Azerbaijan, Kazakhstan, Kyrgyzstan and Pakistan. In 2020, we provided training to crisis teams in Jordan and Iraq and finalized the validation program. During the Covid-19 pandemic, crisis management teams have become a part of our daily business. In addition to prioritizing the health and safety of our employees, we have taken careful steps on the administrative side in terms of epidemic conditions in order to maintain uninterrupted production and distribution activities, with a sense of responsibility to our societies.
In 2021, we have revised our Crisis Management Guide for each country and Group Office (GO). We have provided online training to Azerbaijan IMCR team, and we continue to hold pandemic meetings on a regular basis with IMCR coordinators in all other countries.

Data Security And Privacy

Information Security Governance
CCI runs company-wide information security governance structure that enables the effective management of potential risks and incorporates security and privacy controls into our information systems and services. Information Security Steering Committee, which consists of the Executive Committee and the Security Management Team, acts as the governing body since 2009. CCI implements a comprehensive Information Security Management System (ISMS) based on the ISO 27001 ISMS standard to achieve its security objectives. CCI was certified with ISO 27001 in 2016 and completed the security audit every following year including 2021.
Security
CCI has been running a mandatory cybersecurity awareness program for all employees since 2014, thereby promoting cybersecurity awareness across the company. The awareness program reports are submitted to top management to inform them of any risk.
This awareness program includes online and offline trainings, awareness posters on displays at CCI workplaces, corporate social network groups as well as e-mail notifications on diverse topics such as phishing, travel security, URL security, e-mail security, physical security. Also, we are performing the cybersecurity contests with the prizes for most active employees.

In 2021, CCI has launched a tiered model for training and begun to manage the training model through three basic tiers. The main objectives of the tiered training include ensuring that principles such as “least privilege”, “need to know” and “segregation of duties” are well understood throughout the organization and providing more detailed information on these topics to the leadership.
Privacy and Data Protection
CCI takes precautionary measures to secure the personal information of its employees and customers.
Our IT environment, security measures, policies and cyber security awareness program support compliance with the privacy and data protection requirements.


CCI has complied with Turkish Personal Data Protection Law by fulfilling the requirements and has been registered to the VERBIS system. In order to follow recent regulatory developments and sustain overall compliance, Data Protection and Digital Privacy Committee meets regularly, conducts on-spot audits and reports the results of on-spot audits to top management.
Regulatory Compliance
CCI designed and implemented many initiatives aimed at ensuring compliance with the terms of the below legal requirements:
  • Turkish Personal Data ProtectionLaw no. 6698 (KVKK) and decisions of the Personal Data Protection Institution. Regulation sof other countries for protecting personal data.
  • Communiqués issued by the CapitalMarkets Board of Turkey
  • Compliance with the Law on Regulation of Electronic Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages as well as fulfilling the records requirement for Message Management System.
  • Authorized Economic Operator program by the Ministry of Customs and Trade
  • Law No. 5651 on Regulating Internet Publications and Combating Crimes Committed by Means of Such Publications.
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AN OVERVIEW OF CCI
Our Integrated Governance Approach

Ethics Management

As CCI, our core values are accountability and integrity. It is our wholehearted obligation to protect our most valuable asset; the Coca-Cola brand and CCI.

The CCI Code of Ethics guides our employees to live by our values and “do the right thing”. The scope applies to all CCI operating countries and all employees. CCI also developed the mechanisms for employees and stakeholders to report any illegal or unethical practice within the company to the CCI Ethics and Compliance Officer or the external ethics helpline

Governance Of Ethics

CCI’s Corporate Governance Committee ensures full implementation and enforcement of the Code of Ethics. Implementation of the Code is among the duties of the CCI Ethics and Compliance Manager and the Local Ethics and Compliance Managers. CCI Group Office Ethics and Compliance Committee meets with the participation of all senior management, including CFO, Human Resources Director, the General Counsel, the Corporate Affairs Director and Internal Audit Director.

CCI Ethics and Compliance Manager keep records of all non-compliance incidents across CCI and monitors the review processes and ensures they are completed. Investigations concerning Code of Ethics violations are generally handled by CCI Internal Audit Department handles. In cases of violations of Human Rights Policy, the Human Resources Department conducts investigations and the CCI Ethics and Compliance Committee makes decisions based on the findings of the investigations and its own evaluations. Decision-making authorities may be delegated to Local Ethics and Compliance Committees in accordance with the Guidelines for Handling Code of Ethics Matters.
We impose disciplinary measures that fit the nature and circumstances of each ethic rule violation in accordance with the local legislation of each country. While letters of reprimand are issued for less significant, first-time offenses, violations of a more serious nature may result in suspension without pay, loss of progress payments and bonuses or termination of employment.
For details on Bribery and Corruption management, please see Section 5 –Additional Disclosures for BIST
We offer many channels for our employees to express their concerns on ethical issues.
Website
E-mail
Phone
CCI Ethics Service
  • Is available 24/7 and run by a completely independent third party.
  • Can be accessed through website (in Turkish, English, Russian and Arabic) atwww.cciethicsline.com or a dedicated phone number.
  • Online translation services in Arabic, English, Russian and Turkish are available covering most of the languages used by our employees. For other languages, we receive the notifications which are then translated and recorded.
  • Depending on the employee’s preference, name and e-mail address are kept anonymous and confidential.
Face-to-Face Notification
Employees may direct their concerns to;
» Their managers
» Local Ethics and Compliance Managers.
Depending on the employee’s preference, name and information are kept confidential.
Please click here for details on CCI Code of Ethics.
https://www.cci.com.tr/Portals/3/Documents/PDF/CCI_ code_of_ethics_main.pdf

Please click here for details on CCI Code of Ethics Handbook.
https://www.cci.com.tr/Portals/3/Documents/PDF/code_of_ ethics_handbook.pdf

Our Work in 2021

In 2021, we engaged ourselves in new studies on our policies on relations with third-party stakeholders, gifts and hospitality, and conflicts of interest. Our target in 2022 is to complete the implementation phase for these updated policies and to ensure uniformity in practice across all operating countries.

On the other hand, we continued with the “Integrity Risk Management Program” in collaboration with the European Bank for Reconstruction and Development (EBRD) to mitigate third-party risks to CCI distributors. The second phase of the ethics and compliance management program had already been completed for beneficiary distributors until the break-out of the Covad-19 pandemic. Due to the lingering effects of the pandemic in 2021, the program could not be fully completed; however, we aim to finalize the program in 2022 and extend this initiative by providing an online training catalog with continuous access for businesses, so that they can ensure continuity of their activities.
The legal action to investigate the breach of Law No. 4054 on the Protection of Competition as initiated by the Turkish Competition Authority on Coca-Cola Satış ve Dağıtım A.Ş. has been terminated upon submission of reassuring pledges, which eliminate competitive concerns, by our company to the Authority and acceptance of suchpledges. CCI is committed to operating in full compliance with all applicable competition laws and covenants, as it has been until now.

Training on Ethics

In 2020, we completed our first onlineEthics Training accessible to all CCI employees with full participation, which consisted of five different sections from EtikTV, a platform providing integrated information on Code of Ethics to all employees and covering all aspects of Ethics along with case analyses. We implemented EtikTV in 11 different languages so that each company could excel in Code of Ethics using their own language. Furthermore, EtikTV has now become a part of the orientation program to ensure new hires adopt compliant business processes in terms of CCI Code of Ethics from day one. This year, we are in the process of developing a new refresher to include an overview to ethics concept along with general rules, which should be completed by all employees within the next year.
In 2021, all countries continued with their in-class trainings on ethics. In addition, we organized 20 meetings titled “Compliance Conversations” with participants from all functions and levels, which followed a free format to enable our employees to evaluate ethical processes and share their own opinions on ethical issues, and identified action points for 2022 using the output from these meetings as a guide. We continued to train all employees on Code of Ethics and anti-bribery rules in all CCI countries by using digital boards, internal social media platform to raise awareness. In alignment with TCCC practices, we continued to review and update our Code of Ethics and anti-bribery policy.

Awarness Raising on Ethics

Since 2013, our employees are trained on the revised Code of Ethics, the Code of Ethics Handbook and procedural provisions. The Code of Ethics Handbook and all relevant procedures are made available to our employees. All newly recruited employees are obliged to sign an acknowledgment form confirming that they have read the Code of Ethics and agree to abide by its provisions. All employees are required to periodically make this acknowledgment. Furthermore, we provide all business associates with a document titled “Basic Principles for Suppliers And Business Management Code of Ethics”, which includes the basic principles of CCI’s Code of Ethics, in order to ensure their compliance with our established principles while providing services and supplies so that a uniform approach is employed across all stakeholders in terms of ethics.

Stakeholder Engagement

Building an effective and strong stakeholder dialogue is the core of keeping our business sustainable and engaging them in our sustainability strategy. Since 2013, we have been prioritizing our stakeholders and the means of communication through a comprehensive stakeholder mapping study pursuant to AccountAbility’s AA1000 SES Standard and the EFQM Business Excellence Model.

We engage with each stakeholder group on a regular basis not only to share our sustainability efforts but also to evaluate both our financial issues and to consolidate their opinions and feedbacks. The various means of communication with different stakeholder groups are provided on the following tables.
Stakeholder Day Series
CCI and TCCC envisioned the Stakeholder Day series as a local engagement platform to further improve relations with key local stakeholders, and to raise awareness on our sustainability efforts and manufacturing capabilities of CCI’s operating countries.

Stakeholder Day series was more systematically structured since 2017, when CCI and TCCC representatives came together with the local stakeholders and shared information about the operations and CSR efforts in the region, and CCI’s sustainability vision. 2021 Stakeholder Days had to be postponed to a later date in Bursa, Isparta and Köyceğiz due to Covid-19 measures.
TCCC Reputation Survey
Within TCCC, we plan and implement our actions based on the opinions and feedback of our stakeholders. For this reason, we value the opinions of our stakeholders and conduct a corporate reputation survey periodically with our stakeholders, including our consumers.

In 2021, we held two reputation surveys through a third-party institution using an exemplary grouprepresenting a socially and publicly active influential consumer population in Turkey in accordance with EFQ Mand AA1000 standards. With these surveys, our aim was to examine opinions and attitudes towards Coca-Cola Turkey in an audience segment which drives consumer perception, in terms of issues such as transparency, accountability, financial stability, corporate social responsibility, product and service quality, working conditions, campaigns and advertisements, communication, innovation, environment and company performance.
Anadolu Group’s Corporate Reputation Study
In 2021, Anadolu Group had a corporate reputation study performed involving all Anadolu Group companies, in order to understand the perception and reputation of Anadolu Group as an organization.

The study was performed through a third-party institution and aimed to collect feedback from all our stakeholders about their perspectives and attitudes towards Anadolu Group companies on issues such as reputation index, general corporate perception, criteria-based corporate perception, information resources and communication success. During the study, opinions were collected from a group of stakeholders involving institutional investors and financial circles, media professionals, NGOs and professional organizations, dealerships, university students(scholars), university students(general), bureaucrats, local authorities and members of the parliament, academics, individual investors and the general public.

Communication Platforms With Key Stakeholders

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Materiality Analysis

Materiality analysis is significant to continuously review our performance on issues that are important to us, especially our sustainability priorities, and assess the results annually.

We are aware of the importance of stakeholder participation within the scope of the materiality analysis, thus we engage with each stakeholder group on a regular basis considering their ideas and feedback.

We analyze the material topics under four main titles;
• Global and sectoral risks and opportunities,
• Strategic priorities of CCI and TCCC,
• CCI’s activities and their social, economic and environmental impacts on the value chain,
• Stakeholder concerns and expectations.
Our current materiality matrix, created as a result of our reviews and analyses, is under Executive Committee’s assessment and approval.
In 2020, we organized meetings withour external stakeholders in Turkey,Pakistan and Kazakhstan regardingour targets and commitments for2030, and received their opinionsand feedback.
In parallel with the changing and transforming world conditions during the reporting period, our stakeholders’ impact on evaluation and decision processes as well as the impact dimension for CCI became more prioritized. We reviewed the topics of our 2030 targets and commitments and conducted an online survey with our report advisor at the end of 2021 on our priority topics that would shape the scope of our Integrated Annual Report.
After the surveys were filled out and finalized, we analyzed the results and created a list of priority topics. During our reviews and analyses, we classified important topics into three groups: priority, high priority, and very high priority.After that, we positioned those topics in a matrix from low to highorder by considering the percentage distribution of priority levels for key stakeholders and CCI.
CCI 2021 Materiality Matrix
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Customers & Consumers
Employees
Society and Environment
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Material Sustainability Topics

Consumer Well-Being
We offer a wide beverage portfolio to our consumers that fit in their preferences and at high product quality and safety standards, which has a crucially important place in our business model.
Customer Value
We are determined to continuously increase customer satisfaction with our customer-focused approach and for operational excellence across our geographies with superior supplier management approach.
Human Rights
With our pioneering policies and practices, we are committed to creating an excellent, safe, diverse, equal opportunity workplace that has a positive impact for all employees along our operational value chain.
Human Capital
We listen to the expectations of our employees over various engagement platforms, aim to create a workplace that completely meets their expectations and invest in their development through talent development programs.
Community Development
We are committed to be a responsible corporate citizen, proudly serving the community with our projects focusing on recruitment of youth, women empowerment, water and zero waste issues supported with employee volunteerism and creating positive economic impacts through our investments.
Environmental Footprint
We aim to minimize our impacts on the environment by using fewer natural resources, operating efficiently and generating less waste, intensively focusing on ‘energy management and climate change, ‘water’ and ‘sustainable packaging’ practices.