"As proud as we are of our brands, we take equal pride in marketing our products responsibly. This fundamental operating principle is reflected in our Beam Global Spirits & Wine Marketing Code of Practice. Our goal is to grow our business around the world, leading the way in responsible consumer communications through the highest standards of responsible marketing practices."

Introduction

Beam Global Spirits & Wine proudly produces and markets some of the world's finest beverage alcohol products in many countries around the globe. Production and consumption patterns differ widely from one country or region to another and particularly with regard to different categories of beverages, all of which have their own individual characteristics and place within respective local cultures.

It is with this in mind we have created the Beam Global Spirits & Wine Marketing Code of Practice to communicate our commitment to the responsible advertising and marketing of our brands.

Purpose of Code

The purpose of this global Code is to set the standard for responsible marketing and advertising directed to legal purchase age adults who choose to drink. Our objectives for sales, marketing, promotion and advertising activities are to compete for brand choice with legal purchase age adults who choose to consume beverage alcohol, and to deliver responsible consumer communications that speak to our target, legal purchase age audience.

Our commitment to responsibility is demonstrated by upholding the highest standards in brand marketing and reminding legal purchase age consumers who choose to drink beverage alcohol do so with respect and in moderation. In many countries, there are existing national advertising and marketing codes, laws and regulations, both mandatory and self-regulatory. This global Code is intended to complement these local codes and requirements while also providing responsible company standards in countries where marketing codes and local regulations are not yet developed.

Our Code and the principles it contains will also provide guidance to those with whom we do business to help ensure our brands are marketed and promoted in a responsible manner to legal purchase age adults. We expect and require our partners to employ the high standards we have set in the promotion and sale of our brands.

Scope

Compliance with this Code is mandatory for all units of Beam Global Spirits & Wine, Inc. globally.

• The Code applies to all of our beverage alcohol products.
• The Code applies to all brand advertising (both print and broadcast), consumer communications, trade advertising, promotions (both on- and off-premise), merchandising, brand websites and direct marketing, point-of-sale materials, brand innovation, consumer planning and research, consumer public relations, events, sponsorship activities and product placement.

Basic Principles

Advertising and marketing communications must:

• Be directed to legal purchase age adults who choose to drink beverage alcohol.
• Have content which is designed to appeal to people of legal purchase age and is never intended to appeal to people below the legal purchase age.
• Be placed in media outlets and locations where the audience will be predominantly of legal purchase age.
• Be legal, decent and truthful, conforming to accepted principles of fair competition and good business practice.
• Maintain social and ethical standards with respect to gender and cultural differences among target consumers.
• Reflect Beam Global Spirits & Wine's commitment to social responsibility.

Responsible Consumption:

Advertising and marketing communications must:

• Present our brands to consumers in a responsible manner.
• Not encourage excessive or irresponsible consumption or present abstinence or moderation in a negative way. This applies to the amount of beverage alcohol being consumed as well as the manner in which it is portrayed.
• Never suggest any association of alcohol consumption and violent, daring, dangerous, unruly or anti-social behavior.
• Never suggest any association with illegal drugs or drug culture.
• Not suggest or promote intoxication.
• Not be directed to pregnant women.

Directing Marketing and Advertising to Legal Purchase Age Adults:

Advertising and marketing communications must:

• Be directed to adults of legal purchase age and older.
• Be created so as to appeal to those legal purchase age and older.
• Not depict children or portray objects and images, such as Santa Claus or cartoon figures, that primarily appeal to persons below the legal purchase age.
• Not employ event staff or volunteers below the legal purchase age.
• Not be included in comic pages of newspapers, magazines or other publications directed to those under the legal purchase age.
• Not employ or utilize religion or religious themes in a demeaning manner.
• Not be associated with attainment of adulthood or the "rite of passage" for those under the legal purchase age to reach adulthood.
• Use actors and models in advertisements, promotional materials or point of sale, proven to be at least four years older than the legal purchase age, substantiated by proper identification and must reasonably appear to be over the legal purchase age.
• Not use the term "Spring Break" in promotional related activities or materials. This is a term synonymous with those under the legal purchase age in North America for Spring vacation.

Responsibility Messaging:

Advertising and marketing communications must:

• Illustrate a social responsibility message horizontally. This message should be clearly legible and noticeable for a reasonable consumer. Placement and message will vary across marketing materials and will be determined by the size and material of the communication element. Further guidance is provided by the responsibility messaging guideline document.
• The only exception is when the item is so small that the words would be illegible and no other creative alternatives exist for inclusion.

Hazardous and Dangerous Activity(ies):

Advertising and marketing communications must:

• Not encourage or show excessive or irresponsible beverage alcohol consumption in combination with driving mechanically propelled vehicles.
• Not link beverage alcohol consumption to behavior or activities that would be dangerous while consuming alcohol. This provision applies to operation of potentially dangerous machinery; activities such as swimming, sailing, skiing and horseback riding; or the performance of potentially hazardous activities of any kind which require a high degree of alertness or physical coordination. It is permitted to suggest or depict consumption of beverage alcohol as part of relaxing or celebration after active recreation or labor, as long as the setting and depiction make it reasonably clear that the activity requiring alertness or coordination has ended. One example would be an "après-ski" celebration in a ski lodge.

PERFORMANCE, MEDICAL AND THERAPEUTIC CLAIMS:

Advertising and marketing communications must:

• Not create the impression that consumption of alcohol enhances mental ability or physical performance.
• Not suggest alcohol has special medicinal and therapeutic qualities.
• Not attribute the ability to prevent, treat or cure a human disease with alcohol or refer to such properties.

Alcohol Content:

Advertising and marketing communications must:

• Not misrepresent the alcohol strength of the brand or its alcohol content.
• Only display truthful information on alcohol strength and not emphasize high alcohol strength as a positive attribute of the brand.
• Not imply that consuming brands of low alcohol strength will avoid abuse or intoxication.

Consumer Research Policy:

• Any and all consumer research will be conducted only with consumers of legal purchase age. No effort will be made to learn about consumers' habits, practices, beliefs or any other points of view about alcohol brands as they held them prior to reaching legal purchase age.
• Consumer research from a specific market cannot be utilized in brand planning for markets where the legal purchase age is higher than the legal purchase age in the market where the research was conducted.

Social Content

Advertising and marketing communications must:

• Not suggest the success of an occasion depends on the presence or consumption of alcohol.
• Not contain claims that individuals can attain social, professional, educational or athletic success or status as a result of beverage alcohol consumption.
• Not create the impression that consumption of alcohol will increase confidence, popularity or social success.

Advertising and marketing communications may:

• Be portrayed as part of responsible personal and social experiences.

Sexual Content:

Advertising and marketing communications must not contain or depict:

• Alcohol consumption enhancing sexual attractiveness or as a requirement or enhancement for sexual success.
• Graphic or gratuitous nudity, overt sexual activity, promiscuity or sexually lewd or indecent images or language.

Advertising and marketing may:

• Be portrayed in a manner which depicts people in a social or romantic setting showing affection, or who appear to be affluent or attractive.

Sampling Policy

• Sampling of beverage alcohol must not be offered to those under the legal purchase age.
• Branded merchandise must not be offered to those under the legal purchase age.
• Appropriate age verification must be presented at company-sponsored events to ensure only legal purchase age adults consume beverage alcohol.
• Where local laws and regulations permit, moderate sampling is allowed for legal purchase age adults at licensed, private premises or trade events.

Electronic / Direct Marketing:

Guidelines for Beam Global corporate, brand websites and direct marketing communications:

• Website and email marketing content must be designed to appeal to adults of legal purchase age in the respective country.
• Site gateway pages will display language stating that use is restricted to those of legal purchase age.
• Brand websites must require the viewer to enter date of birth and country of residence on the site gateway page and block access to anyone below the legal purchase age.
• When website visitors are offered the opportunity to opt-in to a brand communications by email or direct mail, as part of the registration process, visitors must be required to affirm they are of legal purchase age.
• Where a national alcohol education site exists, failed entrants to the brand website must be re-directed to a responsible decision-making website.
• A responsible drinking message and link to a responsible decision-making website must appear on each page of all alcohol marketing websites and emails.

Product Placement

Product placement in films, television or theater will be considered if:

• The film, television or theater production has an adult theme or rating.
• Content does not feature underage drinking, excessive drinking or other irresponsible consumption such as drunk driving.
• Content does not feature violent or aggressive behavior linked to alcohol consumption.
• Primary characters appearing in the program are of legal purchase age.

Product placement will only be approved if:

• Sufficient information is provided to prove the specific scene and setting in which the brand(s) will be featured and the overall context in which the brand and the character(s) consuming beverage alcohol in the production are compliant with the social responsibility guidelines outlined in this Code
• Written consent is provided to producer(s) and film company(ies) to use our brands. If a script is deemed inappropriate, written communication must be sent to the relevant party denying permission to use the brand(s).

Promotional Events:

• Promotional events will be conducted only at licensed establishments or at other permitted venues where appropriate safeguards are in place to prevent underage drinking and irresponsible consumption.
• On-premise or off-premise promotions will not support activities that encourage excessive consumption.

Licensing & POS:

The following are examples of items which are inappropriate for POS, merchandising or licensing:

• Children's games, children's toys, children's sporting equipment or other materials primarily targeted towards persons under the legal purchase age, except branded adultoriented games for use at on-premise establishments.
• Children's apparel, clothing or accessories.
• Dolls or action figures whose primary appeal is to those under the legal purchase age.
• Candy, except for fancy chocolates or other confectionary items which are clearly intended for adults.
• Sexual paraphernalia, e.g., condoms.
• Drug-related paraphernalia.
• Guns, knives or items generally referred to as weapons, except tools or cutlery items for culinary purposes and adult sporting activities.

Compliance Procedures:

• All Beam Global Spirits & Wine personnel must adhere to the Code and comply with all provisions of the Code.
• Advertising agencies, market research companies, media buyers and other third parties involved with the marketing and advertising of our brands must receive a copy of the Code and must abide by its provisions in any work they do on behalf of the company and its brands.
• Complaint procedures on marketing and advertising practices for alleged non-compliance with the Beam Global Spirits & Wine Marketing Code is included on the corporate website to allow interested parties to address potential grievances confidentially.
• Beam Global Spirits & Wine will evaluate alleged grievances with regard to compliance of the Code registered with the company and record and respond to parties registering such grievances.
• All regional businesses must establish and adhere to compliance processes to ensure compliance to the letter and the spirit of this Code, local laws and regulations, consumer promotions and privacy laws, intellectual property laws and best practices, and applicable national and regional advertising marketing codes.
• Compliance is required for all marketing, advertising and promotional materials and activities in the on and off trade and is required for brand innovation activities, brand launch campaigns, consumer public relations and all other brand communication activities.
• All Beam Global Spirits & Wine personnel responsible for marketing and promotional materials and activities are required to be trained on the Code and certified and re-certified annually.

Contact Information

For further information on the Beam Global Spirits & Wine Marketing Code of Practice, or other compliance issues, please contact the local in-market general manager or Chris Swonger at chris.swonger@fortunebrands.com.

Beam Global Spirits & Wine
510 Lake Cook Road, Deerfield, Illinois 60015-4964
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