S P E M Y THE CODE OF BUSINESS CONDUCT J E P N S S I. HEINEKEN Policy on

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1 T R P O J M Y TH COD OF BUI CODUCT C T P A I O HIK Policy on

2 Table of Contents Page mployees & human rights management A. Implementation B. Grievance procedures C. Issues of context 4 Our standards related to employees & human rights on-discrimination Freedom of association and the right to collective bargaining Forced labour Child labour Working hours Remuneration Health and safety Harassment Training and personal development ecurity on-complicity in human rights violations 2

3 Policy tatement HIK is the most international brewer in the world. In all countries and societies in which we operate we are determined to act according to our Core Values. Respect for People, the nvironment and the ociety in which we live and work is one of these Core Values. We honor our values by recognizing the responsibility to respect employees & human rights and demonstrating that we act accordingly. The HIK mployees & Human Rights Policy is aimed at supporting and guiding our management and employees to achieve this goal. Introduction In a globalizing world, the role in society of large international companies like HIK is of increasing importance. To ensure that HIK meets its responsibilities in this role, it is amongst others necessary to create and protect a safe and responsible working environment for employees and their direct surroundings. To this end, HIK has developed a policy with regard to the basic employees & human rights that it respects and aims to safeguard. Our respect for individuals and for the well-being of employees is first of all reflected in our Core Values, Business Principles, Code of Business Conduct and Policies (www.thehikcompany.com). This HIK mployees & Human Rights Policy is a further elaboration and articulation of these commitments. HIK endorses the principles enshrined within the Universal Declaration of Human Rights 1 and the Core or Fundamental Conventions of the International Labour Organization (ILO) 2 based on respect for the dignity of the individual without distinction of any kind. HIK supports these human rights and employees rights in line with the legitimate role of business. Where an impact on employees rights falls outside the scope of HIK s responsibility, for instance in case of violations by third parties, HIK will provide assistance to its best abilities. This policy is applicable to all Operating Companies and subsidiaries where HIK holds a majority share or has management control. The provisions of this policy are further explained and accompanied by additional guidelines, designed to specify the details and consequences of the provisions. The further explanation and additional guidelines hence serve as a clarifying background for this policy. For any specific issues or questions concerning third party employees, agency personnel and contractors, we refer to the HIK upplier Code (www.thehikcompany.com) and any other policy that may be applicable and that governs the relationship between HIK and its suppliers or contractors in specific cases. 1. The Universal Declaration of Human Rights, General Assembly of the United ations, 10 December 1948, available at «www.un.org/en/documents/udhr/». Together with the main instruments through which it has been codified, namely the International Covenant on Civil and Political Rights and the International Covenant on conomic, ocial and Cultural Rights, it forms the International Bill of Human Rights. 2. The eight Fundamental Conventions identified by the Governing Body of the ILO, available at «www.ilo.org/declaration/info/publications/wcm_0989/lang--en/index.htm». 3

4 mployees & human rights management A. Implementation Apart from having formulated eleven clear standards on employees & human rights it is important to integrate and implement this mployees & Human Rights Policy and strategy throughout all our Operating Companies in the world. We will focus on: ducation and training The Operating Companies will be trained to raise their awareness of this policy, and they will be supported in their efforts to respect the rights of their employees. Monitoring performance against our own benchmarks Use additional self-assessment tools and develop action plans Facilitate dialogue with stakeholders (such as employees and trade unions) including through clear reporting on the employees & human rights performance of our Company B. Grievance procedures HIK will provide grievance-procedures in all HIK Operating Companies, inform employees about the existence of such procedures and stimulate the proper use of these procedures, while discretion and protection will be guaranteed to those who make use of these procedures. In case of grievances employees are expected to always follow local procedures first, before making use of other channels (e.g. the HIK peak Up procedure). C. Issues of context This policy should be viewed as a minimum standard; where local legislation goes beyond the content of this policy, our Operating Companies will adhere to the local legal obligations. Where compliance with local law can put the Operating Companies into the position of not being able to comply with the standards of this mployees & Human Rights Policy, the Operating Company is expected to act as follows: eek ways to honour the principles laid down in this Policy and try to act according to these principles as much as possible, without acting in direct contravention of local law. If there is a risk that the Operating Company unwillingly contributes to violation of Human Rights, this risk should be treated as a legal compliance issue. In such cases, the Operating Company should contact the legal specialist of Global HR at Corporate Office. 4

5 Our standards related to employees & human rights are: 1. on-discrimination HIK respects the right to non-discrimination. People are employed based on the principle of equal opportunity, without distinction to race, colour, gender, religion, descent or origin. In relation to the appointment or career prospects of employees, HIK will pay attention only to the suitability of the candidate (education, personality, skills, working experience, and other relevant attributes as allowed under local law) and his or her legitimate demands. HIK will take its decisions regarding present and future employees on the basis of objective criteria. HIK respects cultural and individual diversity and promotes inclusiveness. It respects personal beliefs / persuasions of present and future employees. 2. Freedom of Association and the Right to Collective Bargaining HIK respects the right of its employees to be represented in order to advance their legitimate interests. This right includes the right of internal and/or external employee representatives to be acknowledged as partners in negotiations and consultations subject to local laws. Account shall be taken of the nature of industrial relations in the country and the company concerned. In addition, the needs, size and possibilities of the company concerned shall be taken into consideration. HIK considers being represented by a trade union an employee right, not an obligation (the right to choose not to be represented by a trade union). 3. Forced Labour HIK will not engage in or support the use of forced or compulsory labour such as prison labour, debt bondage, trafficking or serfdom. HIK will avoid working with suppliers or employment agencies that are known to be making use of forced or compulsory labour in their operation. 4. Child Labour HIK respects the rights of the child, including the right to education, the right to rest and play and the right to have the child s basic needs met. HIK will therefore not engage in or support the use of child labour, which means that HIK will not allow children to work within its facilities. Furthermore, HIK is committed to and maintains programmes aimed at the elimination of child labour in its supply chain (please also refer to HIK s uppliers Code at HIK follows the ILO definition 3 of the minimum age for admission to employment or work. This age shall not be less than the age of completion of compulsory schooling and in any case not be less than 1 years of age, except in some developing countries where it is 14 years of age. 4 In case local laws set a higher age to define what is considered a child, HIK will abide to the local law. 3. ILO conventions on Child Labour: ILO Minimum Age Convention, 193 (o. 138), available at «http://www.ilo.org/dyn/normlex/en/f?p=1000:12100:0::o::p12100_ilo_cod:c138» and ILO Worst Forms of Child Labour Convention, 1999 (o. 182), available at «http://www.ilo.org/dyn/normlex/en/f?p=1000:12100:0::o::p12100_ilo_cod:c182». 4. Article 2, paragraphs 3 and 4 ILO Minimum Age Convention, 193 (o. 138).

6 . Working hours HIK recognizes the right to rest and leisure and will therefore always comply with local laws, regulations and/or local customs with regard to working hours and overtime. Moreover, in line with the ILO-report of the committee of experts on the application of conventions and recommendations concerning working hours HIK will generally not require its staff to work in excess of a maximum of 48 hours per week (less in some cases, depending on local laws) and will provide at least one day off for every seven-day period*. In this way HIK aims to ensure safety in the workplace and to promote a healthy balance between working and home life of its employees. *In certain exceptional circumstances, there may be specific reasons to deviate from this standard. Prior approval by HIK s Chief HR Officer is required in those cases.. Remuneration HIK observes the statutory minimum wage set by the government of the country in which it has a local operation. Where this is not sufficient to meet basic needs, HIK strives to compensate employees with remuneration that ensures an adequate standard of living. HIK maintains a remuneration policy that emphasizes the internal equity and external comparability within a defined job market. The key elements within HIK s pay and reward policy are: pay for responsibility pay for performance. Health and safety HIK provides its employees with a safe and hygienic working environment and working conditions. HIK will take appropriate measures to continuously improve safety and health aspects within its facilities, including the provision of personal protective equipment when and where necessary. Working conditions should allow for safe working practices and support the occupational health and well-being of employees. We maintain a policy aimed at continuous improvement of our health and safety performance. In those countries particularly developing countries where basic health care is not sufficiently provided by the government and/or if there is no possibility for employees to arrange for basic health care from local service providers themselves, HIK provides or ensures (access to) basic health care itself. HIK has a medical strategy aimed at providing or ensuring (access to) basic health care for its employees and their immediate families.. ILO report of the Committee of xperts on the Application of Conventions and Recommendations (articles 19, 22 and 3 of the Constitution), Report III (Part 1B) Hours of Work, from fixed to flexible?, 200

7 8. Harassment HIK considers protecting personal dignity and health at the workplace to be one of its core responsibilities as a good employer. One aspect of safeguarding the integrity of each employee is to ensure that harassment in any form does not occur and, if it does occur, to ensure that adequate procedures are readily available to deal with the problem and prevent recurrence. 9. Training and Personal Development HIK acknowledges the importance of training and personal development of its employees. Training In general, HIK provides for and bears the costs of - regular training on issues that it finds relevant to the business and/or to the function of the employee. Training and development opportunities for employees will be identified on a regular basis and when considered relevant, training is organised for the employee. Personal development Personal development (employability) is regarded as a shared responsibility for HIK and its employees. This shared responsibility should be reflected in the contribution both parties are prepared to make in financial terms and/or in terms of time invested in additional education and training. HIK encourages its employees to undertake additional training courses and will support them when additional training is considered necessary. HIK will promote policies aimed at the development of skills relevant for its operation and in line with the talents of its employees. 10. ecurity In politically unstable or conflict affected regions, HIK may be confronted with potential security risks to its employees, their dependents and its facilities. When managing security in those situations HIK will respect the rule of law and will adhere to international human rights principles. The company shall prevent its hired security guards from unlawfully infringing on the rights of its employees or of others affected by its operations. When necessary, security guards shall be trained how to behave in such difficult situations and when and how to intervene in security threatening situations. 11. on-complicity in Human Rights violations HIK recognizes that in countries that are politically less stable or where human rights are compromised dilemmas may arise, including whether or how it can continue to operate in that country with integrity. HIK will act in such a way that none of its operations knowingly contribute to human rights violations by others.

8 Administrative information Content Owner Contact ffective as per 1 January 2012 Version 1.1 Global Human Resources Manager Labour Relations & mployment Law T R P O J M Y TH COD OF BUI CODUCT C T P A I O

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