PERNOD-RICARD - URD 2021-22 EN

3. Sustainability & Responsibility Ethics & compliance

Tax policy 3.4.1.5 A significant contribution to local communities The Group commits to complying with all applicable laws and regulations in the countries in which it operates along with applicable international standards. In 2022, Pernod Ricard’s income tax charge on recurring items (profit from recurring operations and financial result from recurring operations) was €651 million. In addition to corporate income tax, Pernod Ricard pays and collects numerous other taxes and contributions as part of the Group’s economic contribution to the communities in which it operates. These include: sales taxes; customs and excise; duties; payroll taxes; property taxes; and other local taxes specific to each country. Pernod Ricard’s total annual contribution is estimated at around €6.7 billion (unaudited data). Approach to taxation The Group applies the following principles in tax matters: support for operational activities 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 subsidiaries in some 74 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 S&R. The Group does not promote any form of tax evasion. Transfer pricing Pernod Ricard’s strategy and organisation are built on a decentralised model with an ongoing relationship between Brand Companies and Market Companies. The Brand Companies generally own, protect and develop the intellectual property. They are also responsible for developing overall brand strategy as well as solutions and ways to activate them. The Market Companies implement this strategy locally. Related-party transactions are done in accordance with the Group’s transfer pricing policy, which is based on the arm’s length principle (6) .

Prevention of anti-competitive practices Pernod Ricard is committed to the public policy goals underpinning Competition law and to acting lawfully in the marketplace. Such concerns are unambiguously addressed in a specific section of the Pernod Ricard Code of Business Conduct, under the label “Compete fairly”. The MOOC also includes a chapter on Competition law. Transparency and integrity of strategies 3.4.1.4 and influencing practices Objectives & Policies Group policy on lobbying is governed by the Code of Business Conduct. The Code was updated in May 2022 and a mandatory e-learning content has been created for employees covering prevention of corruption and bribery. This contains specific rules on dealings with public officials in the chapter related to prevention of corruption. It is also guided by more specific professional Codes (1) and institutional Codes such as the EU Transparency Register (2) , with which Pernod Ricard complies. In addition, specific laws & regulations apply across 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 (3) . It strictly complies with the High Authority’s reporting obligations regarding lobbying activities. Transparency International even acknowledged its detailed reporting practice in their presentation of committed firms. The Group has been a member of Transparency International France since 2013 and actively supports the promotion of transparency and integrity around lobbying and the work being done by this association. It is a signatory to a best practice guide on parliamentary lobbying expenditure. The Group is a proactive signatory of a declaration published on 25 February 2014, 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 strengthened and updated in May 2019, with new signatories reaffirming their commitments (4) . As a result of such commitment and relationship, Pernod Ricard expanded the description of its advocacy priorities and positions on its public facing website this year (5) . This provides more detail to the public as to the public policy options that Pernod Ricard promotes in its dealings with stakeholders. Action plans and next steps Continue to work closely with Transparency International. Roll out the revised version of the Code of Business Conduct across the organisation.

ECPA in Europe, Association pour les Relations avec les Pouvoirs Publics in France, etc. (1) https://ec.europa.eu/transparency-register (2) https://www.hatvp.fr/fiche-organisation/?organisation=582041943#%2 (3) https://transparency-france.org/actu/declaration-commune-entreprises-membres-de-transparency-international-france-lobbying (4) https://www.pernod-ricard.com/en/our-group/our-role-society (5) Arm’s length: terms that would have been agreed between independent parties. (6)

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Pernod Ricard Universal Registration Document 2021-2022