PERNOD RICARD - Universal Registration Document 2019-2020

3. SUSTAINABILITY & RESPONSIBILITY Ethics & compliance

Consumer information 3.3.4.3 Policies and targets

Pernod Ricard is committed to providing quality information to its consumers regarding the ingredients used, the nutritional value of its products, and how to consume them responsibly. On 4 June 2019, spiritsEUROPE – together with Pernod Ricard and several other company members and trade association members in Europe – signed a Memorandum of Understanding (MoU) in the presence of the European Commission. This MoU covers the voluntary communication by European spirits manufacturers regarding the ingredients and nutritional information of products for sale in the EU. The purpose of the MoU is to ensure that the products marketed in the EU by those companies disclose the energy information on the labels and provide the list of ingredients and other nutritional information online. The target was set at 66% of the volume of products marketed in the EU by 31 December 2022. Pernod Ricard aims to exceed the target set by the MoU and has decided to progressively implement it worldwide to all products in its portfolio. This is assuming the communication of such information is not restricted by local laws or regulations. Ethics & compliance 3.4 The Group’s ethical practices 3.4.1 Data privacy 3.4.1.1 Objectives and policies Data privacy, in particular with the entry into force in 2018 of the European General Data Protection Regulation (GDPR) and other similar legislation around the world, is a critical issue for the Group. This issue has significantly affected how Pernod Ricard, in the context of accelerated digitalisation, collects, stores, and manages personal data. It is a business opportunity for Pernod Ricard to ensure the accuracy and relevance of its personal data, to develop consumer trust, secure brand image, and continue to promote its culture of conviviality. It is also an opportunity to rethink and optimise existing processes by adopting best practices regarding personal data retention, management of access, etc. Pernod Ricard has developed governance, tools, procedures, and documentation evidencing compliance, policies, awareness materials in order to cover all major data privacy risks. Pernod Ricard has a strong strategy and data privacy governance in place. A comprehensive data privacy roadmap was drafted ahead of GDPR enforcement and is being implemented across the Group. The Group DPO (Data Protection Officer) and data privacy network enable the Group to implement GDPR compliance, implementing policies and procedures at local level and sharing best practices. This governance structure involves a wide range of stakeholders, including the Group DPO, privacy champions at regional and local level, along with a Data Protection Steering Committee.

As a reminder, all affiliates with a distribution business incorporate the “pregnant woman” warning logo on the labels of all bottles distributed in the EU. In 2006, Pernod Ricard was the first wine & spirits group to proactively extend throughout Europe the application of the logo warning pregnant women to avoid alcohol altogether on its labels. In 2013, Pernod Ricard gradually extended the application of this logo to all bottles distributed by Pernod Ricard worldwide, wherever local country regulations so permitted. Action plans and next steps By December 2020, at least 25% of the volume of Pernod Ricard’s products marketed in the EU will carry the energy information on the label and will provide the ingredients and other nutritional information online. The target will be raised to at least 50% by December 2021, and no less than 66% by December 2022. To implement the digital part of this commitment, Pernod Ricard works with relevant European industry bodies and stakeholders, and GS1 (international organisation specialised in information exchange standards), to make consumer information available online.

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 (mandatory 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).

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Pernod Ricard Universal Registration Document 2019-2020