PERNOD-RICARD - URD 2020-21

____ 3. SUSTAINABILITY & RESPONSIBILITY ETHICS & COMPLIANCE

The Group has been a member of Transparency International France since 2013 and actively supports the promotion of transparency and integrity around lobbying and efforts made 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 who are 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 show leadership through their ethics and corporate social responsibility commitments. This joint declaration on lobbying was reinforced and updated in May 2019, including new signatories who reaffirm their commitments: https://transparency-france.org/actu/declaration- commune-entreprises- membres-de-transparency-international- france-lobbying. Action plans and next steps Maintain its cooperation with Transparency International. Improve description of internal organisation and give more detail on public policy issues on public-facing corporate website. Tax policy 3.4.1.5 A significant contribution to local communities The Group commits to comply with all laws and regulations in force in each of the countries in which it operates, as well as the applicable international standards. In 2021, Pernod Ricard’s income tax charge on recurring items (profit from recurring operations and financial result from recurring operations) was €519 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 €5.7 billion (unaudited data). Approach to taxation The Group applies the following principles in tax matters: support for operational activity in compliance with applicable regulations; integrity in the conduct of tax matters; tax management that is both proactive and efficient to preserve and maximise the value generated for the Group and its shareholders. Pernod Ricard has several subsidiaries in some 73 countries in which it operates. Whenever possible, management makes every effort to liquidate any dormant or quasi-dormant subsidiary inherited from past acquisitions. Pernod Ricard is vigilant as to the operational and commercial reality of its transactions and refuses to take part in any artificial tax arrangements. The Group will only use tax incentives after considering their impact on its brands, reputation and Sustainability & Responsibility. The Group does not promote any form of tax evasion.

SPECIFIC, USER-FRIENDLY DEDICATED DIGITAL TOOLS TO SUPPORT COMPLIANCE EFFORT “Speak Up”: global whistleblowing hotline accessible to all third parties worldwide (Internet or telephone), 24 hours a day, seven days a week, in a wide variety of languages, ensuring confidentiality and anonymity (if allowed by local legislation) to encourage Pernod Ricard stakeholders to raise concerns about, among other things, any corruption-related matter or any breach of the business integrity rules. “Partner Up”: global web-based platform where any employee who may engage the Group in a business transaction, conducts adequate prior verification on relevant third parties. “Gifted!”: the Group’s app to declare and seek approval to give or receive gifts and hospitalities in accordance with the provisions of our Gifts & Hospitality policies. The App has been revisited recently and is accessible on all of our electronic devices. MOOC: training for employees on the Code of Business Conduct. With a “learning by doing” approach, a new mandatory MOOC was kicked off in 2019 to train employees on our updated Code of Business Conduct. This new training was successfully completed by 92% of the mandatory target population during the first campaign ( i.e. all employees with a company-issued electronic device). Since then, the MOOC is a mandatory as part of the onboarding pack for new employees and completion is monitored. 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 3.4.1.4 of strategies and influencing practices Policies and objectives Group policy on lobbying is governed by the Code of Business Conduct, which incorporates specific disciplines on dealings with public officials. In addition, it is guided by more specific 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 addition, specific laws & regulations apply in the countries in which the Group operates. For instance, 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 strictly complies with the High Authority’s reporting obligations regarding lobbying activities. Transparency International even recognised its detailed reporting practice in their presentation of committed firms.

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PERNOD RICARD UNIVERSAL REGISTRATION DOCUMENT 2020-2021