PERNOD RICARD - Universal Registration Document 2019-2020

3. SUSTAINABILITY & RESPONSIBILITY Ethics & compliance

3.4.1.2 Prevention of corruption Integrity, and a zero-tolerance policy against corruption, 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 Alexandre Ricard, applies to all employees. Pernod Ricard’s General Counsel – Compliance Officer is in charge of — structuring and deploying the Group’s comprehensive and robust anti-corruption programme. RULES FOR EMPLOYEES AND OTHER STAKEHOLDERS Pernod Ricard’s Code of Business Conduct : the Code — (accessible on the Intranet and extranet: https://www.pernod-ricard.com/en/download/file/fid/10234/), which includes a chapter related to the fight against corruption, was amended in 2018 in order to address, in particular influence peddling ( trafic d’influence ). It also provides employees and stakeholders with clear, specific examples of potentially sensitive situations. 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 sends all affiliates a self-assessment questionnaire every year, in which they must state whether they are compliant with Group policies. The reliability of the responses to these questionnaires is confirmed in a letter of representation signed by the Chief Executive Officer and Chief Financial Officer of each entity. In addition, the Legal Department works with the internal audit team to conduct a number of compliance audits each year at certain affiliates. Finally, a further task of the internal audit is to verify the Group’s compliance with the rules implemented for the fight against corruption. Whistleblowing policy : employees are invited to speak up about any — potential corruption situation in relation to the Pernod Ricard activities inside or outside the Company. As part of the protection owed to whistleblowers, alerts may be filed anonymously, and we promote a clear non-retaliation policy. Due Diligence policy : our Third Parties are subject to a due — diligence process to determine their compliance risk profile (low, medium or high) to adjust, as appropriate, our contractual and operational relationships to mitigate potential risks. Gifts and Hospitality policy : pre-approval required from the Line — Manager of the employee prior to receiving or offering any gifts or hospitality above a determined amount set at affiliate’s level. 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, 7 days a week, ensuring confidentiality and anonymity (if allowed by local legislation) to encourage the Pernod Ricard stakeholders to alert about any corruption matter. “Partner Up” : global web-based platform to allow any employee who — may engage the Group in a business transaction, to conduct adequate due diligence on the third party.

Prevention of corruption and anti-competitive practices

“Gifted!” : our 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 this year and is accessible on all of our electronic devices. MOOC (Massive Online Open Courses) : e-learning tool providing — training for employees on the Code of Business Conduct. Still driven by the “learning by doing” approach, a new mandatory MOOC was kicked off this year to train employees on our updated Code of Business Conduct. This new training was successfully completed in the allocated time period by 92% of the mandatory target population ( i.e. all employees with a company-issued electronic device) and it is now part of the onboarding pack for new employees. 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 of strategies 3.4.1.3 and influencing practices POLICIES AND OBJECTIVES Group policy on lobbying is guided by 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 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. 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. — Systematically include a component on the ethics of lobbying in the — annual seminar for the global public affairs teams.

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Pernod Ricard Universal Registration Document 2019-2020