Menu

Corporate Governance

CORRUPTION, BRIBERY AND ANTI-COMPETITIVE BEHAVIOUR

(i) Commitment to Anti-Corruption and Anti-Bribery

Carlsberg Group has a zero-tolerance policy against bribery and corruption as we recognise that corruption, especially in cases involving government officials, is one of the key causes of poverty in the world.

We aim to be transparent and an attractive choice for consumers, customers and investors. To this end, the Carlsberg Group has in place an Anti-Bribery and Corruption policy, supplemented by various manuals such as the Anti-Bribery and Corruption manual, Gifts, Entertainment & Donations manual and Third Party Screening manual, to guide the Group in conducting its business in an honest and transparent manner.

For business operations in Malaysia and Singapore, anti-bribery laws are crucial, and they must be strictly complied with to avoid serious financial and reputational consequences. The Group periodically conducts training for employees in addition to raising awareness via internal communications.

It is the Group’s policy that all employees, suppliers, consultants, customers and distributors sign the Anti-Bribery and Corruption declaration before they are employed or engaged by the Group. We have also continued with the mandatory e-learning for all new joiners, with a 100% completion rate in 2022. There were no antibribery and corruption incidents reported in 2022.

(ii) Commitment against Anti-Competitive Behaviour 
The Carlsberg Group supports vigorous but fair play in our business, and never engages in business practices that may infringe competition laws. In Malaysia and Singapore, breaches of competition law will result in severe consequences, including hefty fines, imprisonment and reputational damage.

A competition compliance plan has been developed and implemented by the Carlsberg Group to ensure that we comply with the relevant competition rules and regulations in our daily business operations. This includes the implementation of the Competition Compliance Policy and Manual, e-learning for employees and regular training to raise awareness.

DATA SECURITY AND PRIVACY

The Carlsberg Group recognises the importance of having effective and meaningful data privacy and data protection standards in place, especially when personal data is constantly being collected, used and transferred in our daily work. This is necessary to comply with regulatory requirements, in addition to promoting trust and respect in the individuals whose personal data we collect.

 

For our employees, we are committed to a fair, respectful, safe and non-discriminatory workplace, including lawful handling of personal data as part of our working relationship. For our stakeholders, we collect and use data ethically and in compliance with local laws, including having the necessary privacy policy and notice and a dedicated email address for those who have queries on their personal data. These are embodied in our Data Privacy and Data Protection policy and Data Ethics policy.

The Legal & Compliance Director is the nominated personal data representative of the Group. There were no substantiated complaints concerning breaches of customer privacy and loss of customer data in 2022.

RESPONSIBLE SUPPLY CHAIN MANAGEMENT
Carlsberg Malaysia’s procurement department works with relevant internal teams to perform Supplier Performance Evaluations and is guided by the Environmental Health and Safety (EHS) Safety and Health Compliance Audit. On top of that, we periodically audit suppliers for raw and packaging material, covering aspects such as quality, environment and social responsibility. Our Quality Assurance is charged with the responsibility of deciding which suppliers should be audited, and thereafter, it will conduct the said audit together with our Procurement team.

 

At Carlsberg Malaysia Group, we screen our new suppliers for both environmental and social criteria. In 2022, we screened 100% or 344 of our new suppliers for these criteria. Beyond this, vendors we have contracts with are required to adhere to our Carlsberg Group Supplier Policy and Licensee Code of Conduct, which covers topics such as labour and human rights, health and safety, environmental sustainability, business ethics, competition and fair trade, as well as data protection. Our purchase orders also contain information pertaining to the conduct expected of all our vendors via a code of conduct and a gifts and gratuities policy. We are pleased to report that in 2022, 72% of our procurement spend was on local vendors. We look forward to working with even more local suppliers so that we can deliver shared economic value to the local community, while
leveraging a global network of suppliers.

STAKEHOLDER ADVOCACY
We are guided by Carlsberg Group’s Public and Government Affairs Policy to ensure that our public and government engagement is done ethically and lawfully. Any engagement with external stakeholders, including government officials, has an impact on Carlsberg Malaysia Group’s reputation and our rights to brew, distribute, advertise and sell our products. Our Managing Director, our Corporate Affairs and Sustainability Director and a team of staff thus oversee stakeholder engagement plans, ensuring that these are aligned with and build upon the SAIL’22 strategy.

Even as the economy reopened post-COVID-19, the alcohol industry remained heavily regulated and alcoholic beverages continued to face high excise duty rates. As a brewer, we are committed to working with the government and civil society to develop appropriate interventions, promote healthy habits in relation to alcohol consumption among our consumers and, in turn, minimise
negative externalities from the sale of alcohol.

As Malaysia and Singapore have the second-highest beer excise duty rates in the world, we also consistently engage with the government in hopes that the rates do not increase further, since this would result in more consumers turning to the illicit beer trade. In 2022, we participated in roundtable discussions with various government ministries and agencies who formed part of Malaysia’s Multi-Agency Task Force in combating illicit alcohol and cigarettes to share how the beer industry, including ourselves, has created jobs and livelihoods in Malaysia, and the strides we have made in curbing the negative externalities associated with beer consumption.

We also engage with the government on advertising prohibitions. Notably, we have proactively participated in public consultation exercises conducted by the Communications and Multimedia Content Forum of Malaysia (CMCF), which touch on the topic of responsible advertising. We highlighted the existing measures that we have in place to curb irresponsible online alcohol advertising, and are grateful that the CMCF responded positively to our efforts. Notably, the resulting Content Code 2022 published in January 2022 allowed for alcohol advertisements to be done via electronic based mediums in Malaysia, although such advertisements are not permitted on broadcast mediums such as television, radio and public digital platforms.