PERNOD-RICARD - URD 2021-22 EN

Sustainability & Responsibility Ethics & compliance

Prevention of corruption and anti-competitive practices 3.4.1.3

train employees on the updated Code of Business Conduct. This training was successfully completed by 92% of the mandatory target audience during the first campaign ( i.e. , all employees with a company-issued electronic device). Since then, the MOOC is mandatory as part of the onboarding pack for new employees and completion is digitally monitored. Detection Gifts and Hospitality policy : approval is required from the Line Manager or the affiliate’s designated key contact prior to receiving or offering any gifts or hospitality above a determined amount set at affiliate level. “Gifted!” : the Group’s app to declare and seek approval to give or receive gifts and hospitality in accordance with the provisions of the Gifts & Hospitality policies. The app is accessible on all electronic devices. Whistleblowing policy : employees and stakeholders are invited to speak up about, amongst other things, any potential corruption involving Pernod Ricard activities inside or outside the Company. As part of the protection offered to whistleblowers, alerts may be filed anonymously, and the Group promotes a clear non-retaliation policy (see Subsection 3.4.2.3 “Whistleblower system”). Pernod Ricard's whistleblowing policy is underpinned by the global whistleblowing line: “Speak Up” . It is accessible to all third parties worldwide (Internet or telephone), 24 hours a day, seven days a week, in a wide variety of languages. It offers confidentiality and anonymity (where 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 rules set forth in the Code of Business Conduct. Internal control principles : they apply to all Group affiliates and specify that all Pernod Ricard affiliates must comply, among other things, with the Pernod Ricard Code of Business Conduct and the Procurement Code of Ethics. Pernod Ricard annually sends a self-assessment questionnaire to all affiliates. In this, they must state whether they are compliant with Group policies. The reliability of the responses is confirmed in a letter of representation signed by the Chief Executive Officer and Chief Financial Officer of each entity. Control & assessment In addition, the Legal Department works with the internal audit team to support the compliance audit stream in the annual audit cycle. Finally, internal audit is also tasked with monitoring Group compliance with the rules in place to fight corruption and influence peddling. Remediation Each time a breach of the Code of Conduct rules is confirmed following an internal investigation, a wide range of remediations and mitigating measures may be decided by management, including disciplinary sanctions on any employee responsible for such misconduct. The Group promotes a zero tolerance on breaches of internal rules and values and may – in accordance with local labour laws, decide to apply sanctions up to termination of employment.

Prevention of corruption Integrity and a zero-tolerance policy against corruption and all related misconduct 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 the Chairman and CEO, applies to all Group employees. Pernod Ricard’s Chief Ethics & Compliance Officer is in charge of structuring and promoting the Group’s comprehensive and robust anti-corruption programme. Corruption & influence peddling risk map update In 2022, Pernod Ricard updated its Group corruption and influence peddling risk map, and presented the results to the Executive Board, the Executive Committee and the Audit Committee. Involving more than 1,440 employees, over 300 workshops worldwide, this project covered a full perimeter and generated a new corruption and influence peddling risk map that is an accurate reflection of the Group's operational & geographical realities. A comprehensive programme designed to protect against, detect and assess specific risks Prevention Pernod Ricard’s Code of Business Conduct : the Code (1) was overhauled in 2022 to be more practical and easier to use. It still includes, in particular, a section on anticorruption and business integrity in general. The new Code also covers other topics such as competition law, prevention of insider trading and conflicts of interest, but also health & safety, diversity & inclusion, speaking on social media, data ethics, harassment, bullying, confidentiality and Sustainability & Responsibility. It provides for practical advice on how to behave in real life situations, and whom to reach in case of doubt. Group anti-bribery policy: in accordance with the French 2016 Sapin II law, the Policy specifically details the Group’s rules to prevent, deter and detect public and private corruption and influence peddling risks. It also provides employees and stakeholders with clear, pragmatic examples of potentially sensitive situations. Prior verification policy : Pernod Ricard’s Third Parties are subject to a due diligence process to determine their compliance risk profile (low, medium or high), allowing the Group to adjust, as appropriate, contractual and operational relationships to mitigate potential risks. Various levels of verification are set out under the procedure, depending on the initial risk assessment of each relationship category, as identified by Pernod Ricard’s Sapin II risk map on corruption and influence peddling. This due diligence process is implemented via “Partner Up” , the Group's global web-based platform where any employee engaging the Group in a business transaction can conduct adequate prior verification on relevant third parties. Online training: training for employees on all chapters of the Code of Business Conduct. With a “learning by doing” approach, a new mandatory MOOC was kicked off in 2019 to

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Accessible on the Intranet and Group’s website: (1) https://www.pernod-ricard.com/sites/default/files/inline-files/PR%20Code%20of%20Business%20Conduct%20-%20ENGLISH%20Version% 20-%20June%202022%20_0.pdf

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Pernod Ricard Universal Registration Document 2021-2022

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