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SUSTAINABILITY & RESPONSIBILITY (S&R) DEVELOP COMMUNITIES AND INVOLVE OUR PARTNERS

act as ambassadors for responsible drinking and behave impeccably ● in all professional situations. More specifically, the Group lobbying policy complies with professional Codes (EPACA in Europe, Association pour les relations avec les pouvoirs publics in France, etc.) or institutional Codes (http://ec.europa.eu/). The Company’s Vice-President of Government Affairs is responsible for the oversight and implementation of this policy. The main lobbying actions are approved by the Group’s Chairman & CEO and the rest of Senior Management is kept informed on the status of the projects. The organisation chart of the Institutional Affairs team, guidelines on lobbying and the main stances on current issues in this area are available on the Pernod Ricard website in the section “Our practices: Public Affairs”. A training course on lobbying, part of which focuses on ethical issues, can be found in the Pernod Ricard University brochure under Lobbying, the art of influencing. Part of the course is delivered by Transparency International (http://www.transparency.org/), of which Pernod Ricard has been a member since early 2013. It aims to train participants in: ensuring that lobbying practices are transparent and responsible; ● defining a series of recommendations for representatives of ● interests; ensuring that lobbying practices comply with the Group’s S&R ● commitments. Although it is open to all, this training course is primarily aimed at employees who interact with public authorities and national and international organisations, specifically affiliate Chief Executive Officers, those working in public affairs, communication professionals, S&R leaders and so on. In France, Pernod Ricard is a signatory of the joint declaration on lobbying presented by Transparency International’s corporate members (https://transparency-france.org/project/declaration-commune-entreprises- membres-de-transparency-international-france-lobbying/). Pernod Ricard is a joint signatory to a good practice guide on parliamentary lobbying expenditures published by Transparency International (https://transparency-france.org/wp-content/uploads/2016/07/Guide-de- d%C3%A9claration-des-d%C3%A9penses-en-lobbying-desgn.pdf). Regarding interactions with public authorities, the requirement for high ethical standards is an integral part of the Group’s Charter and the Code of Business Conduct, which, as set out above, covers all of the Group’s activities and not just lobbying. Furthermore, in the European Union, Pernod Ricard has been registered in the Register of Representatives of Interests since its creation in 2008, under ID number 352172811-92. This register contains useful information about teams, budgets, areas of interest, membership of associations, etc. (http://ec.europa.eu/transparencyregister/public/consultation/display lobbyist.do?id=352172811-92&isListLobbyistView=true). In France, Pernod Ricard has also been registered on the list of representatives of interests established by the High Authority for Transparency in Public Life since the list’s creation in 2017. See file https://www.hatvp.fr/fiche-organisation/?organisation=582041943##. This discloses Pernod Ricard’s affiliations to organisations that are themselves representatives of interests, the funding set aside for lobbying and other measures taken in general. The positions defended on this occasion can be found on the Pernod Ricard website, as indicated below. Lobbying activities in the United States are highly regulated at federal level and also at state and municipal level. Pernod Ricard conducts its lobbying activities in full compliance with applicable US laws, including the Lobbying and Disclosure Act of 1995, the Honest Leadership and Open Government Act of 2007 and the Federal Election

Campaign Act of 1971. In addition, Pernod Ricard complies with the various ethics rules adopted by the US Senate, the US House of Representatives and the agencies of the Executive Branch. Pernod Ricard is required under US law to file quarterly and half-yearly reports on its lobbying activities and political contributions with the Secretary of the Senate and the Clerk of the House of Representatives. In addition, the Pernod Ricard USA Political Action Committee is required to file regular reports, which are in the public domain, with the Federal Election Commission. Secretary of the Senate: www.senate.gov/legislative/lobbyingdisc.htm ● #lobbyingdisc=lda; Federal Election Commission: www.fec.gov/data/. ● Stances on regulatory issues 3.4.2.4 Generally speaking, Pernod Ricard has no particular stance on regulatory issues other than those taken officially and communicated by our trade associations worldwide. In some cases, the Group may take a specific position on issues of particular interest. The issues for us relate to trade, alcohol and health, taxation and communication. In general, the policies we uphold are covered on the websites of our trade associations, for example: on intellectual property: European Brands Association www.aim.be; ● on marketing matters: World Federation of Advertisers, ● www.wfanet.org; for sector-specific matters: spirits EUROPE (www.spirits.eu); Comité ● européen des entreprises vins (www.ceev.eu/); Scotch Whisky Association (www.scotch-whisky.org.uk); Fédération des exportateurs de vins & spiritueux de France (www.fevs.com); Distilled Spirits Council of the United States (www.discus.org); Winemakers’ Federation of Australia (www.wfa.org.au); the Industry Association for Responsible Alcohol Use in South Africa (https://aware.org.za/); Association of Canadian Distillers (www.spiritscanada.ca/); Thai Alcohol Business Association; EU Chamber of Commerce in China, Agriculture, Food & Beverage Working Group (www.europeanchamber.com.cn); International Alliance for Responsible Drinking (IARD) (www.iard.org). Our representatives are occasionally invited to events where they publicly speak about regulatory issues. Pernod Ricard’s main stances are available in the section “Our practices: Public Affairs” on the Group’s website: www.pernod-ricard.com. Tax policy 3.4.2.5 A significant contribution to local communities Pernod Ricard is one of the world leaders in the Wine & Spirits industry, with a unique portfolio of Premium international brands among the most comprehensive in the market. As such, the Group complies with all laws and regulations in force in each of the countries in which it operates, as well as the applicable international standards. In 2018, the Group Pernod Ricard’s income tax charge on recurring items (profit from recurring operations and financial result from recurring operations) was €520 million. In addition to corporate income tax, Pernod Ricard pays and collects numerous other taxes and contributions, including sales taxes, customs and excise duties, payroll taxes, property taxes and other local taxes specific to each country, as part of the Group’s economic contribution to the communities in which it operates. Pernod Ricard’s total contribution is estimated at around €5.9 billion (unaudited data).

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PERNOD RICARD REGISTRATION DOCUMENT 2017/2018

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