Our program is driven by innovation and empowered by state-of-the-art data analytics tools such as BrewRIGHT, our innovative and award-winning compliance analytics solution. It works to aggregate, standardize and visualize multiple company systems to identify, detect and prevent fraud and corruption within our operations. It applies machine learning to improve models and optimize performance.

In 2019, we significantly increased the adoption of BrewRIGHT in our Zones. Each Zone reviewed thousands of transactions to improve the machine learning models of the platform. An agile working model helped to accelerate the development and improvement of several BrewRIGHT dashboards.

The capabilities of BrewRIGHT have expanded with the integration of machine learning and improved algorithms from rule-based tests, driving transparency and providing a platform to support proactive usage by internal stakeholders, collaboration and behavior. These expanded capabilities have allowed our Ethics & Compliance team to work in a more agile style, improving efficiencies and engagement. Moving forward, a key challenge will be to make BrewRIGHT real-time predictive, which tests on our machine learning model.

In 2019, the BrewRIGHT Antitrust rollout included the trial of a dashboard which displays antitrust risks across all of our markets in real time, enhancing conventional audit tools such as interviews and document reviews. The system simulates thousands of hours of legal and economic review across systems to assess information about commercial activity fed into the system and prioritizes activity that warrants the most compliance scrutiny. The data analytics not only rank which trends to focus on but assign a risk score to each identified risk pattern, for a holistic view of the company’s overall antitrust risk.

BrewRIGHT Antitrust analytics was shortlisted for two awards at the FT Innovative Lawyers Awards Europe 2019.

In 2019, we overhauled some of our policies in order to bring additional clarity to our rules and drive more transparency across our operations. For example, the Anti-Corruption Policy states we have zero tolerance towards bribery and corrupt conduct in any form. This policy prohibits both active and passive bribery and other corrupt payments in both the public and commercial sectors. It supplements the general provisions set out in the Company’s Code of Business Conduct and is designed to help colleagues comply with the US Foreign Corrupt Practices Act, the UK Bribery Act, other applicable laws against bribery and corruption as well as various government conflict of interest and public disclosure laws.

We strive for effective communication in elevating awareness of ethics and compliance issues, including anti-bribery, anti-corruption, anti-harassment and discrimination, conflicts of interests, antitrust, and digital ethics. To this end, we used digital innovation to make training more productive and enjoyable by transitioning our training approach from a slide deck presentation to interactive animations that portray possible scenarios based on real life cases. The online training was supplemented with live sessions and internal communications.

Additionally, we leveraged our partnerships with universities and antitrust experts to pilot our Antitrust Academy with teams in certain zones. We look forward to further expanding its coverage.

In 2019, we continued to revise our digital ethics and data privacy strategies and agenda with a cross-functional approach in order to ensure it moves along with our digital transformation.