PERNOD RICARD - 2018-2019 Universal registration document

3.

SUSTAINABILITY & RESPONSIBILITY Ethics & compliance

Examples of data privacy actions Promotion of data privacy as an integral part of the Group’s culture, — through global awareness campaigns (including videos and newsletters) and employee training (MOOC and customised training sessions). Comprehensive documentation to ensure consistent and — comprehensive implementation of data privacy and common standards based on a global data privacy policy, adapted for local requirements, along with detailed procedures and toolkits. Implementation of privacy by design and by default on new projects — and specific privacy documentation on major projects ( e.g. development of the latest version of the consumer database; development of an online consumer profile centre). Prevention of corruption 3.4.1.2 and anti-competitive practices Prevention of corruption Integrity, and a zero-tolerance policy against corruption, have long been part of Pernod Ricard’s core values. Unambiguous tone from the top The Pernod Ricard Code of Business Conduct, prefaced and endorsed — by Alexandre Ricard, applies to all employees. Pernod Ricard’s General Counsel – Compliance Officer is in charge of — structuring and deploying the Group’s comprehensive anti-corruption programme. Rules for employees and other stakeholders Pernod Ricard’s Code of Business Conduct : the Code (accessible — on the Intranet and extranet: https://www.pernod-ricard.com/en/our-commitments/public-affairs/), which includes a chapter related to the fight against corruption, was amended in 2018 in order to address influence peddling ( trafic d’influence ), as well as providing employees and stakeholders with clear, specific examples of potentially sensitive situations. Internal control principles : they apply to all Group affiliates and — specify that all Pernod Ricard affiliates must comply with 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; Whistleblowing policy : employees are invited to speak up about — any potential corruption situation in relation to the Pernod Ricard activities inside or outside the Company, with a confidential process protecting them effectively from any retaliation. Gifts and hospitality policy : pre-approval required from the Line — Manager of the employee prior to receiving or offering any gifts or hospitality above a determined amount set at affiliate’s level.

Specific, user-friendly dedicated digital tools to support compliance efforts “Speak Up” : global whistleblowing hotline accessible to all third — parties worldwide (Internet or telephone), 24 hours a day, 7 days a week, ensuring confidentiality and anonymity (if allowed by local legislation) to encourage the Pernod Ricard stakeholders to alert about any corruption matter. “Gifted!” : an app rolled-out in most of the Pernod Ricard affiliates, — accessible on smartphones or on personal computers, to declare and authorise gifts and hospitalities in accordance with the provisions of the Gifts and Hospitality Policy. MOOC (Massive Online Open Course) : e-learning tool providing — trainings for employees about corruption and internal control principles, based on educational videos produced by experts from the Legal Department and questions based on “learning by doing” approach. Prevention of anti-competitive practices Pernod Ricard is committed to the public policy goals of Competition laws and to acting lawfully in the marketplace. Such concern is unambiguously addressed in a specific chapter of the Pernod Ricard Code of Business Conduct. The MOOC also includes a chapter on Competition law. Transparency and integrity 3.4.1.3 of strategies and influencing practices Policies and objectives Group policy on lobbying is guided by professional Codes (ECPA in — Europe, Association pour les relations avec les pouvoirs publics in France, etc.) and institutional Codes such as the EU Transparency Register (https://ec.europa.eu/transparency-register), with which Pernod Ricard complies. In France, the Group is registered on the list of representatives of interests established by the High Authority for Transparency in Public Life (https://www.hatvp.fr/fiche-organisation/?organisation=582041943#%23). It complies strictly with the High Authority’s lobbying activities reporting obligations; Transparency International even recognised its detailed reporting practice in their presentation of committed firms. The Group has been a member of Transparency International since — 2013 and actively supports the promotion of transparency and integrity around lobbying and actions led by this association. It is a signatory to a best practices guide on parliamentary lobbying expenditure'. Proactive signatory of a declaration made public on 25 February 2014 — initiated together with seven companies all members of Transparency International France. This declaration is open to all companies, business federations, professional associations, trade unions and NGOs (members and non-members of Transparency France) who wish to move forward on this subject and show an example through their commitments under their ethics and social responsibility policy or governance. This joint declaration on lobbying was reinforced and updated for its — publication in May 2019, including new signatories who renew their commitments: https://transparency-france.org /actu/declaration-commune-entreprises-membres-de-transparency -international-france-lobbying. Proactive member of Friends of Transparency EU Forum since 2017 — (https://transparency.eu/about/friends/)

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PERNOD RICARD UNIVERSAL REGISTRATIONDOCUMENT