PERNOD RICARD - 2018-2019 Universal registration document

3.

SUSTAINABILITY & RESPONSIBILITY Ethics & compliance

Risk assessment procedures

3.4.2.3

Human Rights

Health and safety

Environment

Group’s own operations

Principles and procedures of internal control and riskmanagement are described in Section 2 “Corporate governance and internal control” The “iSay” survey (p. 96) Protection of insured capital and the prevention of major industrial risks: more than 60 industrial sites audited each year (p. 117)

Annual audit of Brand Companies as part of their ISO 14001 certification (p. 109)

Complaints handling system (see p. 109). External audit the Responsible Marketing Panel (p. 111) Annual audit of Brand Companies as part of their OHSAS 18001 and ISO 22000 certification

Supplier and subcontractor activities

Blue Source process (p. 98)

Early warning andwhistleblowing 3.4.2.4 system To provide employees with day-to-day support, Pernod Ricard encourages dialogue and trust, allowing everyone to express their point of view and voice their concerns. The Group’s Code of Business Conduct advocates a “Speak-up policy”, calling on all employees to inform management of any suspicions they might have regarding a practice or situation deemed to be contrary to or inconsistent with this Code, the associated policies or any legal or regulatory standard. During FY19, Pernod Ricard launched a Group-wide early warning system titled Speak-Up to allow people who wish to warn the Group to do so in a safe and confidential manner. Hosted by a third party, it is available 24 hours a day, seven days a week. Any report deemed to be serious is the subject of an internal analysis and investigation conducted under the aegis of an Integrity Committee comprising the following Group-level functions: Legal, Internal Audit, Human Resources and S&R. If any violations are identified, the Integrity Committee examines their severity and decides on the measures to be taken. Pernod Ricard ensures that no disciplinary action is taken against anyone reporting a violation in good faith.

Monitoring system for themeasures implemented Pernod Ricard has monitoring procedures and systems in place for Human Rights, health & safety and the environment. The aim is to ensure that the monitoring plan is properly implemented and continually updated: internal reporting system and indicators for monitoring the — implementation of the actions undertaken. The results have already been extensively published and audited with complete transparency in this report (see Sections 2, 3 and 4 in particular); the role of the Nominations, Governance and CSR Committee is to — assess the relevance of the Group’s S&R commitments and to oversee their implementation. 3.4.2.5

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2018-2019

PERNOD RICARD UNIVERSAL REGISTRATIONDOCUMENT