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

The Group’s ethical practices 3.4.2 Corruption prevention 3.4.2.1 Pernod Ricard’s commitment to combating corruption has historically been expressed through several documents. These documents include: Pernod Ricard’s Charter, in particular the business model chapter, ● which specifies that all employees must abide by the legislation in their market and by the Group’s policies and procedures; Pernod Ricard’s Code of Business Conduct, which currently covers ● eight key chapters of the Group’s compliance programme (combating corruption, gifts and hospitality, competition law, combating money laundering, conflicts of interest, insider dealing, protection of personal data, use of digital technology, media and social networks, and brand protection) and which will shortly be enhanced by two new chapters entitled “Trade sanctions” and “Doing business with integrity”. Available in French, English, Spanish, Russian and Portuguese, this Code states unambiguously that “Doing business with integrity has long been one of Pernod Ricard’s core values and commitments”, and applies a principle of zero tolerance on corruption. The Code has been circulated to all employees and is available on the Pernod Ricard website under the section “Our commitments/Public affairs” at the Pernod Ricard site: www.pernod-ricard.com/en/our-commitments/ public-affairs/; Pernod Ricard’s Procurement Code of Ethics, which notably contains ● the Code of Conduct principles to be observed in respect of gifts and hospitality; the 10 th principle of the United Nations Global Compact, which states ● that “Businesses should work against corruption in all its forms, including extortion and bribery”; the United Nations Sustainable Development Goals adopted in ● September 2015 to end poverty, protect the planet and ensure prosperity for all, particularly goal 16, which aims to “Substantially reduce corruption and bribery in all their forms”; the OECD guidelines for multinational enterprises, where ● anti-corruption measures are addressed in Chapter 7 (www.oecd.org/daf/inv/mne/48004323.pdf). Pernod Ricard has also adopted an anti-bribery policy that applies to all Group companies. Brand Companies and Market Companies are required to establish systems and controls to comply with this policy, which may include the adoption of local versions of the Group policy. An Ethics Committee made up of the Group General Counsel, the Executive Vice President, Human Resources, Sustainability and Responsibility and the Managing Director in charge of Finance and Operations meets as often as is necessary. Its mission is to ensure that the roll-out of the anti-corruption policy within the Group is monitored and controlled, and to make changes to it if necessary. Pernod Ricard’s internal control principles, which apply to all Group affiliates, specify that all Pernod Ricard affiliates must comply with the Pernod Ricard Charter, the Pernod Ricard Code of Business Conduct and the Procurement Code of Ethics. Pernod Ricard sends all affiliates a self-assessment questionnaire every year, in which they must state whether they are compliant with Group policies. The reliability of the responses to these questionnaires is confirmed in a letter of representation signed by the Chief Executive Officer and Chief Financial Officer of each entity. In addition, the Legal Department works with the internal audit team to conduct a number of compliance audits each year

at certain affiliates. Finally, a further task of the internal audit is to verify the Group’s compliance with the rules implemented for the fight against corruption. Furthermore, two online training modules are now accessible to all Group employees. These training courses, delivered as MOOCs (Massive Online Open Courses), cover: the current eight chapters of the Pernod Ricard Code of Business ● Conduct, including anti-corruption measures. Specific training on these topics is also delivered locally, as required; the principles of internal control implemented within the Group, ● including with regard to preventing corruption. Prevention of anti-competitive practices 3.4.2.2 Pernod Ricard’s policy is to always act and do business in compliance with applicable laws and regulations. This policy is included in the Pernod Ricard Charter. With regards to compliance with competition laws, the Charter states: “Pernod Ricard is committed to the public policy goals of competition laws and to acting lawfully in the marketplace. It is the Group’s policy to observe both the letter and the spirit of the competition laws in all countries where we do business. Wherever one is located in the world, competition laws will apply to the way the Group conducts its business. Specifically, it is prohibited to fix selling or purchasing prices with our competitors or any other terms on which we trade. Not only are explicit agreements between competitors to fix prices prohibited, but also informal coordination of price level increases and the exchange of price information. Similarly, agreements or understandings with competitors to divide up markets or territories are illegal.” These principles are set out in the chapter on “Competition Rules” of the Pernod Ricard Code of Business Conduct, and listed in the Pernod Ricard Policy on Compliance with Competition Law, where more details and practical examples are given. In addition, the MOOC online training platform also includes a module on “Compliance with Competition Law”. Lastly, the Pernod Ricard principles of internal control, applicable to all Group affiliates, require that the affiliates comply with the Pernod Ricard Charter and accordingly prevent any anti-competitive practice. Transparency and integrity of strategies 3.4.2.3 and influencing practices All Pernod Ricard employees are subject to the provisions of the Pernod Ricard Charter, and specifically to its rules of ethics (in the business model chapter of the Charter), which is one of the Group’s three key values. The Charter states that Pernod Ricard expects all its employees to have a strong sense of ethics, with “respect” and “transparency” as watchwords. All employees are required to: abide by the applicable legislation in their market and by the Group’s ● policies and procedures; be honest and trustworthy by being sincere and open about their ● actions; treat colleagues, shareholders, customers, consumers, suppliers and ● competitors with the greatest respect; respect the environment; ● comply with our industry commitments; ●

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PERNOD RICARD REGISTRATION DOCUMENT 2017/2018