Training Nestlé employees involved in marketing of breast-milk substitutes are regularly trained on the WHO Code.

Nestlé has developed a unique global programme to ensure compliance with the WHO Code across all Nestlé’s operations.

GES Investment Services, Northern Europe’s leading analysis firm for socially responsible investments, published a report on “The Infant Food Industry and the WHO Code”. This report is the first of its kind assessing and comparing infant food companies’ compliance procedures with respect to the WHO Code. It concluded: “Nestlé has the most elaborated policies and mechanisms to address the Code, distinctly ahead of its peers”.

Nestlé's implementation of the WHO Code includes the following:

• Nestlé Policy and Instructions
• Training, testing and compensation on WHO Code knowledge
• Nestlé WHO Code Management System
• Internal Ombudsman System
• Internal and External Audits
• Internal and External Reporting

Nestlé Policy and Instructions
First published in 1982, these were developed to ensure complete and correct implementation of the WHO Code by Nestlé. This became necessary because the WHO Code, as a recommendation to governments, does not supply implementation instructions. This is left to national regulation, which may be absent or weaker than the WHO requirements.

Training, testing and compensation on WHO Code knowledge
Nestlé trains personnel involved in marketing of breast-milk substitutes on the WHO Code, monitors its own practices, identifies contraventions and takes corrective action. Personnel are tested regularly on their knowledge of the WHO Code, and their performance on the tests is a criterion upon which salary increases and promotions are based. Code violations are also taken into account regarding decisions on salary increases, promotions, and if serious enough, lead to termination of employment.

Nestlé WHO Code Management System
In all developing countries, Nestlé has implemented an extensive WHO Code Management System, built along the lines of ISO quality assurance systems. The manual, outlining Nestlé policies and procedures, gives detailed operational guidelines to all Nestlé employees in their daily conduct of business related to Infant Food to ensure compliance at all levels with both the WHO Code of Marketing of Breast-milk Substitutes and local regulations. The procedures include built-in checks to ensure that potential code violations are avoided.

Internal Ombudsman System
Each Nestlé Market has a designated Ombudsman, outside of line management, to whom suspicions of WHO Code violations can be reported in a confidential manner.

There is also a Corporate Ombudsman, who is a member of the Executive Board of the Nestlé Group, to whom employees can report allegations if they are uncomfortable with reporting them to their market’s ombudsman.

Internal and External Audits
Internal audits on WHO Code compliance are carried out in about 20 countries each year by corporate auditors. Nestlé employees are informed that their actions are subject to audits and that Code violations may result in punitive measures. Audit results are communicated to top management, and where violations occur, these are reported to the Nestlé CEO.

In addition, Nestlé commissions external audits on code compliance on an ongoing basis. Since 2004, Bureau Veritas, a major global auditing company, has been commissioned to review Nestlé infant food marketing in several countries in Africa, Asia and Latin America. Learn more about the results of these external audits.

Internal and External Reporting
Internal and external summary reports on Nestlé's compliance with the WHO Code and with the Nestlé Policy and Instructions are prepared annually.