PERNOD RICARD - 2018-2019 Universal registration document

3.

SUSTAINABILITY & RESPONSIBILITY Ethics & compliance

ResponsibleMarketing Panel (RMP) Ethical control over advertising is the responsibility of the RMP. Created in 2005, the RMP is in charge of screening all advertising material due to be rolled out. It is composed of five people and a secretary general. They are all independent from the Marketing Department, and monthly report to the Executive Committee. Two members of the Executive Committee have an arbitral status and are also consulted on any changes to the CCC or the drafting of implementing guidelines. All commercial communications must be submitted to the RMP which must statute upon it within seven days. All decisions are taken collectively by the RMP’s members and are binding on everyone in the Group. In case of doubt about a campaign submitted for approval, the RMP has the right to request an opinion from the local or regional advertising regulatory authorities of the markets concerned. The Panel provides formal opinions on every campaign submitted: approval of the campaign, approval subject to modification, or rejection, in which case the campaign must be re-submitted. An e-learning on the CCC was launched in 2014 with a mandatory status for marketers, legal and CSR functions. Since the Panel was set up in 2005, 2719 campaigns were reviewed, and 1768 confidential advices were requested. For 2019, 153 formal requests over which 148 received a green assessment. 112 copy advices were received. Action plans and next steps With the implementation of the Pernod Ricard CCC, the Group will continue to deliver a brand experience of Convivialité and responsibility in compliance with industry commitments and advertising authority requirements. The Group will update its CCC and relaunch the e-learning in October 2019. Guidelines for the CCC will be rolled out in 2020. Consumer information 3.3.4.3 Policies and objectives Pernod Ricard is committed to providing quality information to its consumers on the ingredients used, the nutritional value of its products, and how to consume them responsibly.

On 4 June 2019, spiritsEUROPE  (1) – together with Pernod Ricard and several other European company members and trade association members – has signed a Memorandum of Understanding (MoU) agreed with the European Commission regarding the voluntary communication losure by the European spirits companies of the ingredients and nutritional information of their products sold on the European market. The objective of the MoU is to ensure that the products placed on the European Union's markets by those companies disclose the energy information on the label of their products and provide the ingredients and other nutritional information online. The target was set at 66% of the products placed in the EUmarket by 31 December 2022. Pernod Ricard has the ambition to go beyond the target set by the MoU and has decided to progressively implement it worldwide – where the communication of this information is not restricted by local legislations or regulations – and to all the products of its portfolio. You are reminded that all affiliates with a distribution business incorporate the “pregnant woman” warning logo on all bottles distributed in European Union countries. In 2013, Pernod Ricard gradually extended the application of this logo to all bottles distributed by Pernod Ricard worldwide (notwithstanding regulatory constraints). Action plans and next steps By December 2020, 25% of Pernod Ricard’s products placed on EU market will carry the energy information on-label and will provide the ingredients and other nutritional information online. The target will be increased to 50% by December 2021, and 66% by December 2022. To implement its commitment to provide information online, Pernod Ricard cooperates with the global supply chain standardisation body GS1 to make consumer information available online.

Ethics & compliance 3.4

The Group’s ethical practices 3.4.1 Data privacy 3.4.1.1 Objectives and policies Data privacy, particularly the General Data Protection Regulation (GDPR), is a critical issue for the Group. This issue has significantly affected how Pernod Ricard, in the context of increasing digitalisation, collects, stores, and manages personal data. It is a business opportunity for Pernod Ricard to ensure the accuracy and relevance of its personal data, to develop consumer trust, secure brand image, and continue to promote its culture of conviviality. It is also an opportunity to rethink and optimise existing processes by adopting best practices regarding personal

data retention, management of access, etc. Pernod Ricard has developed governance, tools, procedures, and documentation evidencing compliance, policies, awareness materials in order to cover all major data privacy risks. Pernod Ricard has a strong strategy and data privacy governance in place. A comprehensive data privacy roadmap was drafted ahead of GDPR enforcement and is being implemented across the Group. The Group DPO (Data Protection Officer) and data privacy network enable the Group to implement GDPR compliance, implementing policies and procedures at local level and sharing best practices. This governance structure involves a wide range of stakeholders, including the Group DPO, privacy champions at regional and local level, along with a Data Protection Steering Committee.

spiritsEUROPE represents one of Europe’s most valuable agri-food export sectors and, with it, the interests of 31 associations of spirits producers as well as nine leading multinational (1) companies – for more information on spiritsEUROPE, see https://spirits.eu.

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PERNOD RICARD UNIVERSAL REGISTRATIONDOCUMENT