We are fully committed to compliance with applicable laws and regulations and doing the right thing consistently, without compromise. To ensure ethical and legal compliance, we provide annual online training on our Code of Conduct to salaried associates with e-mail accounts, who must certify that they have read and understand the Code and agree to abide by it. In 2010, approximately 57,000 associates in this target group completed this training and certification process in 26 languages. Our Code of Conduct awareness efforts also included in-person training for more than 100,000 associates outside of the target group.

Distributed to associates, either electronically or in hard copy, our Code of Conduct is translated into 42 languages. In addition to our 2010 ranking as one of the world's most ethical companies by Ethisphere magazine, we also ranked in the top quartile for compliance performance for the beverage industry in the 2010 Dow Jones Sustainability World Index.

Human Rights Policy

PepsiCo's Human Rights Workplace Policy seeks to ensure a work environment that is free from all forms of discrimination, and where people feel comfortable and respected. In 2009 and 2010, we translated this policy into 10 additional languages and broadly communicated it as a part of our Code of Conduct training, a leading-edge process that ensures our businesses are operating in the most ethical way possible. Currently, the Human Rights Policy is available in 42 languages.

As a signatory to the United Nations Global Compact, PepsiCo is also visibly committed to all of its 10 principles, including those for Human Rights and Labor Standards. In addition, we provide a Supplier Corporate Social Responsibility Assurance Program, which contains human rights and labor-standard guidelines.

Please visit PepsiCo's Human Rights Workplace Policy section to learn more.

Foreign Corrupt Practices Act (FCPA) Anti-Bribery

PepsiCo has an International Anti-Bribery Compliance Policy that prohibits giving or promising money, gifts, gratuities, meals, entertainment or anything of value to a foreign government official to influence that person's decisions or gain an unfair advantage. In 2010, over 22,000 international associates completed a mandatory web-based anti-bribery training course, which was available in 26 languages. All trainees certified understanding and compliance to the International Anti-Bribery policy.

The online anti-bribery training initiative was supplemented throughout 2010 by a series of targeted "train-the-trainer" presentations followed by small-group, in-person training workshops in key locations worldwide. In 2010, employees in China, India and Vietnam have completed the training through in-person workshops.

Commercial Bribery and Business Gifts

PepsiCo's Worldwide Code of Conduct, Worldwide Gifts Policy and Travel and Entertainment Policy all prohibit bribery and unethical business practices. The Code and policies prohibit employees from giving or accepting a gift to or from a customer or supplier unless it is nominal in value and frequency; there is a legitimate business purpose; the gift is in good taste, consistent with accepted business practices, is not offered to gain an unfair advantage and will not create an appearance of impropriety or embarrass PepsiCo; and the gift is permitted by PepsiCo's policies and the law. Similar rules govern the giving or receiving of meals and entertainment.

Political Contributions Policy

PepsiCo's Political Contributions Policy applies certain criteria to any PepsiCo contributions made to political candidates or entities in the U.S., and all such contributions must be made in accordance with applicable campaign finance and disclosure laws. Corporate contributions and donations are made through the PepsiCo Concerned Citizens Fund, which is supported by employee donations. An explanation of how candidates are selected is available online at www.pepsico.com/company/Corporate-Governance.

Human rights policy violations can be reported to Human Resources, the PepsiCo Law Department or by using Speak Up, a confidential program, through which associates can raise questions or concerns by phone or Internet. PepsiCo uses an outside provider to receive all calls and web reports. The system is operated 24 hours a day and is available on both internal and external websites and can be accessed via phone through toll-free numbers in 58 countries and in 36 languages or by collect call.

We encourage associates to report issues such as discrimination, harassment and mistreatment of associates when they occur. Moreover, PepsiCo forbids retaliation against persons who report wrongdoing. In addition, in the U.S., PepsiCo is providing inclusion training to associates, including all managers. During the training, we explore the human rights intrinsic to all and the importance of sustaining an inclusive culture.