Coca-Cola Amatil SOCIAL MEDIA POLICY

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1 Coca-Cola Amatil SOCIAL MEDIA POLICY September 2012

2 Policy: Social Media Policy Approval Date: 17th September 2012 Approved By: Sally Loane Version: 1.2 Amendments: Minor change Previous Version: 1.1 Previous Approval Date: 8th May 2012

3 Contents Page 1. Social Media Policy 2. Scope Definitions Speaking on Behalf of CCA in Social Media 5. Talking About CCA in Social Media Use of Company Branding in Social Media Use of Internal Social Media Platforms Use of External Social Media Platforms 9. Personal Responsibilities When Participating in Social Media Consequences of Breaching the Social Media Policy 06 Media and Public Affairs Team Contacts 07

4 1. SOCIAL MEDIA POLICY The Social Media Policy operates in conjunction with the Code of Business Conduct, the Media Contact and Public Speaking Policy, the Disclosure and Communication Policy, the Privacy Policy, the Computer Usage Policy, Information Protection Policy and the Working Together Policy. Should any conflict arise between the Social Media Policy and the Code of Business Conduct, the Code of Business Conduct will prevail. 2. SCOPE The Social Media Policy ( Policy ) relates to all full-time, part -time and casual employees within the Coca-Cola Amatil group of companies [Coca-Cola Amatil (Aust) Pty Limited, Coca-Cola Amatil Limited and SPCA] ( CCA Employees ), as well as contractors, temporaries and subcontractors working for or on behalf of either company or any associated companies in the CCA workplace ( CCA Associates ). The Policy also applies to CCA Employees and CCA Associates participation in social media inside or outside of any CCA workplace (that is, social media activities anywhere in the world), in so far as such participation makes reference to CCA, CCA Employees and/or CCA Associates. The Policy does not form part of any CCA Employee s contract of employment. Nor does it form part of any CCA Associate s contract for service. 3. DEFINITIONS SOCIAL MEDIA Social Media and social media platforms are the terms commonly given to websites, Weblogs (blogs), online tools and other Interactive Communication Technologies which enable users to interact with each other in some way. Social Media platforms are often characterised by the principles of participation, community, conversation and connectedness, and may be hosted within CCA systems or on the external public internet. The term Social Media and Social Media Platforms includes, but are not limited to: Podcasts; Wikis (e.g. Wikipedia); Social Networks (e.g. Facebook, MySpace); Business or Professional Networks (e.g. LinkedIn, XING); Blogging Sites (e.g. Blogger, WordPress); Micro Blogging Services (e.g. Twitter) Instant Messaging Services (e.g. MSN, Google Chat); Message Boards; Content Sharing Services (e.g. YouTube, Flickr); and Social Bookmarking Websites (e.g. del.icio.us) The term hand held device includes all devices which are used by CCA Employees and CCA Associates inside and outside working hours, in the workplace of CCA or at any other place. Such devices include but are not limited to: Mobile phones Blackberrys Palm Pilots PDAs iphones any other smart phone Tablets ipads, and other handheld electronic devices. 2 SOCIAL MEDIA POLICY

5 4. SPEAKING ON BEHALF OF CCA IN SOCIAL MEDIA As a publicly-listed company, it is important that factual and consistent information is presented to the media, investor and general public by CCA. CCA must also protect commercially sensitive information in accordance with the confidentiality agreement between CCA and each CCA Employee and CCA Associate as detailed in the terms and conditions of their employment (or contractual arrangements). To meet these objectives, CCA restricts the number of people who are permitted to make public comment on its behalf. This includes making comments on behalf of CCA in any social media platform. Speaking on behalf of CCA may include, but is not limited to, stating the Company s views, disclosing new information or commenting upon an industry issue. The only Company Officers and CCA employees authorised to speak externally on behalf of the Company to the media or on social media are the Chairman, Group Managing Director, Chief Financial Officer, Investor Relations Manager or Director of Media and Public Affairs. THE POLICY IN PRACTICE THE SITUATION: An employee has an argument with their manager and posts about it on Facebook. The employee makes extremely rude comments about the manager and makes a threatening comment. Although the manager is unable to see the comment, as they are not friends on Facebook, several other employees of CCA see the comment, and the Manager finds out. THE OUTCOME: This is a breach of the Social Media Policy, the Code of Business Conduct and Working Together Policy. The situation was investigated and the person was subject to a formal disciplinary process. THE SITUATION: An employee blogs that CCA is against a newly released legislation, and misrepresents the Company s views about how the industry is reacting. The employee did not have formal permission to speak on behalf of CCA. THE OUTCOME: This is a breach of the Social Media Policy. The situation was investigated and the employee was subject to a formal disciplinary process. THE SITUATION: You attend a work related function with fellow CCA employees and decide to check in all CCA employees you are friends with on Facebook without their permission. You also tweet about the event and post photos of you and your colleagues. One of your colleagues received a lot of criticism for being tagged at the event, and the inappropriate photos are ed to others. THE OUTCOME: Please ensure you have your colleagues permission before tagging them or posting photos of them. Ensure your privacy settings are restricted. Without permission from your colleagues, this is a breach of the Social Media Policy. SOCIAL MEDIA POLICY 3

6 5. TALKING ABOUT CCA IN SOCIAL MEDIA CCA recognises that circumstances may arise in which CCA Employees and CCA Associates make mention of CCA in social media. However, it is important for CCA Employees and CCA Associates to make it clear that they are not representing CCA nor are they an authorised spokesperson of CCA and the views expressed are the personal views of the CCA Employee/CCA Associate alone and do not represent the views of CCA. Where appropriate, a disclaimer should be included. If a CCA Employee or CCA Associate is commenting about CCA when they are not an authorised spokesperson, they must observe the following: 5.1 CCA S REPUTATION CCA Employees and CCA Associates are not to make comments which might reflect negatively on CCA s reputation. False information published in social media can easily be verified and, as a result, damage may occur to a CCA Employee s or CCA Associate s personal credibility and that of CCA. CCA Employees and CCA Associates must not make deliberately false or misleading claims about CCA, its products or services which may reflect negatively on the Company s reputation. This extends to making deliberately false or misleading claims about CCA s competitors. If a CCA Employee or CCA Associate makes a comment which is shown to be inaccurate, all reasonable efforts must be made by the CCA Employee or CCA Associate to correct the statement. This may include, but is not limited to, issuing a clarification, an apology or retracting the comment. If a CCA Employee or CCA Associate is unsure about the accuracy of a comment they are proposing to make, they should consult their immediate Manager or the Media and Public Affairs Team before publishing it on a social media platform. 5.2 DISCLOSURE OF COMMERCIALLY SENSITIVE OR CONFIDENTIAL INFORMATION If a CCA Employee or CCA Associate is unsure about the commercial sensitivity of any information, they must consult their immediate Manager or the Media and Public Affairs Team. 5.3 CCA s CLIENTS, PARTNERS AND SUPPLIERS CCA Employees and CCA Associates must not endorse any client, partner or supplier of the Company without the explicit permission of the Director of Media and Public Affairs. In addition, CCA Employees and CCA Associates must not cite or reference clients, partners or suppliers without their approval. 5.4 COMPLIANCE WITH PRIVACY, DEFAMATION AND COPYRIGHT LAWS CCA Employees and CCA Associates should observe the relevant privacy, defamation and copyright laws. CCA Employees and CCA Associates may be held personally responsible for any content they upload or contribute to social media platforms, regardless of their intention. CCA Employees and CCA Associates are encouraged to carefully consider their comments before publishing them on social media as it will remain public for a very long time. 5.5 CONSIDERATION OF AUDIENCE CCA Employees and CCA Associates must not make contributions that are inflammatory or offensive, such as, but not limited to, ethnic slurs, obscenities, offensive material or personal insults. CCA Employees and CCA Associates must also not engage in any conduct which could be interpreted as harassment, intimidation or bullying, or any other behaviour which constitutes a breach of the Code of Business Conduct or Working Together Policy. Under no circumstances are CCA Employees or CCA Associates to disclose confidential or commercially sensitive information on any social media platform. This extends to any use or participation in social media by a CCA Employee or CCA Associate after they leave CCA. 4 SOCIAL MEDIA POLICY

7 6. USE OF COMPANY BRANDING IN SOCIAL MEDIA CCA Employees and CCA Associates must not use company branding (including the corporate logo, internal logo and registered trademarks) to create any form of online content or imply any form of sanctioned corporate communication without the express permission of the Director of Media and Public Affairs or an authorised member of the Media and Public Affairs Team. This extends to the branding of products owned by CCA. The use of CCA-owned product branding in social media by Brand or Trade Marketing Teams will be at the discretion of the relevant Brand Manager or Trade Marketing Manager, provided it does not breach compliance with the relevant CCA product brand guidelines. All enquiries relating to the use of the CCA corporate logo must be directed to the Media and Public Affairs Team. CCA Employees and CCA Associates must also not use any registered trademarks of The Coca-Cola Company ( TCCC ) without permission from an authorised TCCC representative. Any unauthorised use of company branding should be reported to the Director of Media and Public Affairs. 7. USE OF INTERNAL SOCIAL MEDIA PLATFORMS CCA has its own internal social media platforms, including, but not limited to, wikis, blogs and instant messaging services. Content uploaded to internal social media platforms is intended for internal audiences only and must not be distributed to any person outside of CCA under any circumstances. All areas of the Policy which apply to external social media also apply to internal social media. CCA Employees and CCA Associates should refrain from uploading or contributing content to internal social media platforms which contains commercial in confidence or sensitive material. Participation in CCA internal social media platforms by CCA Employees and CCA Associates must also be in compliance with the Code of Business Conduct, Computer Usage Policy, Privacy Policy, Information Protection Policy and Working Together Policy. POLICY IN PRACTICE THE SITUATION: An employee blogs on a community site within CCA. The comments are appropriate and related to the community site. THE OUTCOME: This is acceptable and not a breach of the Social Media Policy. THE SITUATION: An employee has a LinkedIn account and ads the CCA logo to their account, hoping to attract more connections. THE OUTCOME: It is a breach of the Social Media Policy to use company branding including logos. The situation was investigated and the employee was subject to a formal disciplinary process. THE SITUATION: A sales employee is angry at a customer who was not very friendly. The employee posts a comment on Facebook saying : Thanks Joe Smith at XYZ Chicken Shop for ruining my day! Gotta love crappy CCA customers!. THE OUTCOME: This comment is unacceptable and at the very least breaches the Social Media Policy and Privacy Policy. The situation was investigated and the employee was subject to a formal disciplinary procedure. SOCIAL MEDIA POLICY 5

8 8. USE OF EXTERNAL SOCIAL MEDIA PLATFORMS When using external social media platforms, including, but not limited to social networks and blogging sites, CCA Employees and CCA Associates should not disparage or make adverse comments or contributions about CCA, any CCA Employee or any CCA Associate. This includes where such comments or contributions are made whilst a CCA Employee or CCA Associate is contributing to a social media platform using a CCA computer and internet resources and similarly whilst using a non-cca computer or hand held device. CCA Employees and CCA Associates should be aware that, in accordance with the Computer Usage Policy, internet usage is continuously logged and archived by CCA for monitoring purposes, on an ongoing basis. If it comes to CCA s attention that a CCA Employee or CCA Associate has made inappropriate and/or unauthorised comments about CCA or a CCA Employee or CCA Associate, CCA may choose to take action against such person as outlined in the Policy. Action will not be limited to contributions made on a social media platform made whilst using a CCA computer and CCA internet resources but may include action taken as a consequence of inappropriate and/ or unauthorised contributions made about CCA, a CCA Employee or a CCA Associate via a non-cca computer or hand held device. 9. PERSONAL RESPONSIBILITIES WHEN PARTICIPATING IN SOCIAL MEDIA CCA views CCA Employees and CCA Associates to be personally responsible to report any inaccurate, misleading or deceptive information they encounter about CCA, its products and services and, where appropriate, positively support CCA s products and services when participating in social media. Whilst CCA s Consumer Information Centre Team conducts regular monitoring of social media platforms, it is the responsibility of every CCA Employee and CCA Associate to immediately report any inaccurate, misleading or deceptive information about CCA, its products and services to the Media and Public Affairs Team. Inaccurate, misleading or deceptive information can spread quickly throughout social media platforms and it is paramount that all reasonable efforts are made to report and correct this information swiftly. CCA also encourages CCA Employees and CCA Associates, where possible, to positively support CCA s products and services, for example, speaking positively or promoting a particular product. In doing so, CCA Employees and CCA Associates must be mindful of disclosing that they are an employee or associate of CCA. 10. CONSEQUENCES OF BREACHING THE SOCIAL MEDIA POLICY Any breach of the Policy may result in disciplinary action, including, but not limited to, issue of a warning, demotion, suspension or termination of employment (or, for CCA Associates, the termination or non-renewal of contractual arrangements). Where a breach of the Policy also involves a breach of one or more of CCA s policies, for example the Disclosure and Communications Policy, disciplinary action may be taken in accordance with the respective policies. 6 SOCIAL MEDIA POLICY

9 MEDIA AND PUBLIC AFFAIRS TEAM CONTACTS All enquiries relating to the Policy should be directed to the following members of the Media and Public Affairs Team. Director of Media and Public Affairs Phone: Mobile: SOCIAL MEDIA POLICY 7

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