Living Our Values WIN THE RIGHT WAY

Transcription

1 Living Our Values WIN THE PERFORMING AT OUR VERY BEST

2 2 Need to to Ask Ask a a Question or or Raise Raise a a Concern? Concern? Pg. Pg Recognize and and protect protect Confidential Information Information Pg. Pg Use Company Company Resources appropriately appropriately Pg. Pg Maintain trust trust and and integrity integrity in in your your Business Business Relationships Pg. Pg. 9 9 Actively Actively support support our our goals goals for for Health, Health, Safety Safety and and the the Environment Pg. Pg Act fairly and and lawfully lawfully with with Customers Customers and and Competitors Competitors Pg. Pg. 7 7 Avoid Conflicts Conflicts of of Interest and and act act in in the the company s company s best interests interests Pg. Pg Treat others with with Respect Respect and and Equal Equal Opportunity Opportunity at at Work Work Pg. Pg Be a positive role role model model for for Alcohol Responsibility Pg. Pg. 5 5 Keep Accurate Records Records for for your your area area of of responsibility Pg. Pg. 3 3 Get approval approval before making making Political Contributions Pg. Pg Know and follow follow the the rules rules for for Trading Trading in in Company Company Stock Stock Pg. Pg Living Our Values Win the Right Way A message from Peter Swinburn, CEO At Molson Coors, we are focused on becoming a top four global brewer. Our Brew is the compass that will get us, and keep us, heading in the right direction. It truly defines who we are and how we ll work together towards accomplishing our goals. As we say in Our Brew, we have a duty to ourselves, the communities we live in, the suppliers we work with, the customers we serve and the beer drinkers we seek to delight to always do the right thing. Another guide to doing the right thing is our Code of Business Conduct, Living Our Values. Together with our Values, the Code helps us ensure we are right on Brew with our decisions and actions. Throughout this document, you ll find links to policies, examples of the right way and wrong way to live out the Code and some helpful ideas on how you can connect the Code to our values excelling, passion, integrity & respect, creativity and quality. These examples come from some real life challenges, but since we can t anticipate every situation, we ve also included information on how to get some advice if you have questions or concerns about anything related to the Code. We must all be committed to the principles outlined here and in Our Brew. When we are living our Values and following the Code, we are performing at our very best, and we will win the right way. Cheers! Peter

3 Living Our Values Keep accurate records for your area of responsibility 3 The Code Accurate reporting is essential to ensure the integrity of our books and records, run the company more effectively and effi ciently and comply with the law. We are responsible for maintaining complete, accurate and timely books and records related to our areas of responsibility. This includes things like forecasts, time cards, expense reports, production and quality records as well as our financial statements. We are also expected to be familiar with and to follow all internal controls and to give full cooperation to auditors. I am working on a potential deal for the company and the contract I m considering has some unusual terms. I contacted my business partner in Accounting to make sure they were aware and could advise me on the right way to record it in our books. Turn to next page for Tell Me More MCBC Finance Policy Library Ethics and Compliance Helpline Ethics and Compliance Website More ways to connect our values to Accurate Records

4 Living Our Values Keep accurate records for your area of responsibility 4 Excelling Doing the things that are key to winning is built on a foundation of trust and consistency that depends on always having accurate information about the company. Passion Everyone needs to understand the requirements for books and records in their area. What do they mean for your team? How can you make them more consistent, reliable and relevant? Integrity & Respect Being open and transparent with each other and in our books and records helps to create trust at all levels of the organization and with our outside stakeholders. Creativity Accuracy in books and records is not just about compliance. Research has shown that teams that have high standards on the every day things, such as reports and records, really excel at implementation of new ideas and processes. Quality Accuracy in our records helps us operate more efficiently and spend more company resources at what we do best making beer. I am working on a potential deal for the company and the contract I m considering has some unusual terms. I contacted my business partner in Accounting to make sure they were aware and could advise me on the right way to record it in our books. I am hiring a contractor to work on a small project. I am authorized to approve up to $10,000, but the expected cost is $18,000. I completed the procurement form by splitting the commitment into smaller amounts in order to approve it myself. After all, it s not that big of a difference and I don t want to hold up the work by getting additional approval.

5 5 Whenever I am hosting a company event, I try to provide non-alcoholic beverages and food in addition to a selection of our great beers. I make sure the event has a designated start/end time, watch for signs of overconsumption and arrange alternative transportation for anyone who needs a ride at the end of the evening. Living Our Values The Code We promote responsible use of our products by adults of legal drinking age. Even the appearance of condoning underage drinking, drunk driving or other irresponsible activity is unacceptable. While working, entertaining for the company, or otherwise representing Molson Coors, our behavior refl ects positively or negatively upon our reputation and our brands. So, if we choose to consume or serve alcohol beverages, we are expected to set a positive example. Tell Me More Global Employee Alcohol Responsibility Policy Ethics and Compliance Helpline Ethics and Compliance Website Living Our Values Turn to next page for More ways to connect our values to Alcohol Responsibility Be a a positive positive role role model for for Alcohol Responsibility

6 Living Our Values Be a positive role model for Alcohol Responsibility 6 Whenever I am hosting a company event, I try to provide non-alcoholic beverages and food in addition to a selection of our great beers. I make sure the event has a designated start/end time, watch for signs of overconsumption and arrange alternative transportation for anyone who needs a ride at the end of the evening. I noticed one of my co-workers had too much to drink at an event and probably needed a ride home. But I didn t feel comfortable saying anything, and I figured someone else would probably handle it. Excelling Responsibility is part of our brand so look for opportunities to excel at responsibility, such as being the designated driver, providing rides home or cab vouchers at events where our products are served. Passion Don t apologize for acting responsibly it s something to be proud of! Integrity & Respect Integrity requires taking action, even when it s uncomfortable. That may mean speaking to a manager about a co-worker who drinks excessively at company events, or going out of your way to may sure someone gets home safely. Creativity Pairing up wonderful foods with our products, beer tastings and providing non-alcoholic beverages at an event creatively highlight our brands while promoting responsible consumption. Quality Be as obsessive about responsibility as you are about quality. All of us can have an impact. What are you doing? Could you do more?

7 Living Our Values Act fairly and lawfully with Customers and Competitors 7 The Code At Molson Coors, we win the right way vs. winning at all costs. We act in an honest, fair and objective way in our communications with customers and competitors and we always compete fairly in the marketplace. This means that we must: Acquire customers and competitive information through good work, not illegal or unfair practices. Always take the high road; and not talk badly about a competitor. Never talk with a competitor or potential competitor about pricing, market, territory, production or customer information. I belong to a professional association where I occasionally run into some people from competitor organizations. At one meeting, some of them began discussing recent pricing challenges. I explained that engaging in this type of discussion was against my company policy and left the meeting. In rare cases, governments don t enforce trade practice regulations, and that might put us at an unfair competitive disadvantage if we follow unenforced rules and our competitors do not. In these situations, or anytime we are unsure about the right course of action, we must get guidance from the Legal Department. Turn to next page for Winning at all costs can ultimately hurt both our bottom line and our reputation. It s up to all of us to ensure Molson Coors wins the right way. More ways to connect our values to Customers and Competitors Tell Me More Legal Department website Global Competition Law Policy Ethics and Compliance Helpline Ethics and Compliance Website

8 Living Our Values Act fairly and lawfully with Customers and Competitors 8 I belong to a professional association where I occasionally run into some people from competitor organizations. At one meeting, some of them began discussing recent pricing challenges. I explained that engaging in this type of discussion was against my company policy and left the meeting. My neighbor owns a bar down the street that currently doesn t list any of our products. I offered him a cash incentive in exchange for his agreement to list our products and we were able to introduce several brands. Passion Excelling Amaze your customers by going the extra mile on service rather than providing illegal incentives. Show your passion for the beer business. Passion can be infectious, and we believe it is a competitive advantage for Molson Coors. Integrity & Respect Compete with integrity. Highlight the positive qualities of our product and never say something false or misleading about them or about a competitor s product. Creativity Challenge yourself and your team to come up with a new and creative way to differentiate us from our competitors. Quality Be able to explain about the quality of our products and why they stand out from the rest. Highlight these facts to your customers at every opportunity.

9 Turn to next page for More ways to connect our values to Business Relationships 9 Is it consistent with good business practice, given and received openly and transparently? Does it give the appearance of infl uencing a business decision? Before I give or accept any gift, I ask myself these questions: Does it violate any laws, regulations, the Code or any other company policies? Is the value nominal and within my local policy limit? If I don t get the right answers, I don t do it. Is it too frequent? Maintain trust and and integrity integrity in in your Business Business Relationships Relationships Living Our Values The Code Building and maintaining trusted business relationships is critical to winning in beer. Gifts and entertainment can be appropriately used to thank customers, distributors and suppliers for working with Molson Coors. However, when it appears that we are trying to unfairly influence a business decision, it damages our reputation. If we work with suppliers, customers or distributors, we must stay independent and impartial in our relationships. We cannot give or receive gifts, money or entertainment in exchange for a favor or to influence a business decision. We re a global company and must also follow anti-corruption laws of other countries as well as the U.S. Foreign Corrupt Practices Act. These laws bar us from promising, offering or making payment in money, products or services (anything of value) to anyone in exchange for favorable treatment. Tell Me More Global Anti-bribery & Corruption Policy Global Travel & Entertainment Policy Local Gift & Entertainment Policy Ethics and Compliance Helpline Ethics and Compliance Website

10 Living Our Values Maintain trust and integrity in your Business Relationships 10 Excelling Doing things better than anyone else means we can build and maintain our business relationships the right way. Passion It s easy to get caught up in the passion around our business, but always stay impartial and balanced in your dealings with suppliers, customers and distributors. Creativity Integrity & Respect Use this test How would this look in the newspaper? If you don t like the headline, don t do it. Showing your appreciation doesn t always have to include a gift. Take the time to send a handwritten note to a supplier that went above and beyond with a separate one to their boss. They will really appreciate it! Quality The quality of our decisions must be as important to us as the quality of our beer. Make sure your decisions are free of any unfair influence. Before I give or accept any gift, I ask myself these questions: Is the value nominal and within my local policy limit? Does it give the appearance of infl uencing a business decision? Is it too frequent? Is it consistent with good business practice, given and received openly and transparently? Does it violate any laws, regulations, the Code or any other company policies? If I don t get the right answers, I don t do it. I love the Rolling Stones and they are coming through town on their last tour, but tickets are impossible to get. I happened to mention this to an agency partner I was working with and they said they could get the tickets for me at no charge! I was happy to accept them; after all, I give that agency a lot of business and deserve something once in a while.

11 11 To make sure I am handling information appropriately, I ask myself these questions: Is this information known outside the company? Is it proprietary to us or to one of our business partners or suppliers? Would our company be disadvantaged or harmed if others knew this information? If I think the answer is yes to any of these, I treat the information as confidential and take the necessary steps to protect it. Living Our Values The Code Many of us work with confi dential information about the company. That information is often the key to differentiating us from our competitors recipes, marketing plans, financial information, strategic materials and trade secrets. Sharing confi dential information with people outside the company can hurt us competitively, damage our reputation or impact our financial results. Even inside the company, don t discuss confi dential information with other employees except on a need-to-know basis. Some of us may also have access to personal information of fellow employees, or confi dential information about a business partner or supplier that we must also protect. If your job or the project you are working on involves such information, you may be asked to follow additional measures to safeguard information. Turn to next page for More ways to connect our values to Confidential Information Recognize and and protect protect Confidential Information Information Tell Me Me More More Global Network & & General General IT IT Security Security Policy Policy Global Global Disclosure Disclosure Policy Policy Global Safe Safe Harbor Harbor Privacy Policy Policy Global Records Records Management Policy Policy Global Information Classification Classification Policy Policy Ethics and and Compliance Compliance Helpline Helpline Ethics and and Compliance Website Website

12 Living Our Values Recognize and protect Confidential Information 12 Excelling In addition to the daily things, such as putting away your files before you leave work and locking down your computer, take the initiative to clean out your area and properly dispose of confidential information that is no longer needed. Passion Protect company information with the same passion you have about protecting your own personal information. Integrity & Respect Many of us work with people who work with confidential information. Instead of asking them How does the bottom line look for next quarter? or Is there any truth to that acquisition I hear rumors about? Respect their position and don t ask them something you know they can t share. Creativity Confidential projects (such as new business ventures or restructurings) can be the very thing that people most want to hear about. Think creatively. What can be shared with fellow employees without compromising the confidentiality of the information? Quality Know how to properly identify information that is confidential or sensitive and follow the required steps in our policy for classifying and protecting it. To make sure I am handling information appropriately, I ask myself these questions: Is this information known outside the company? Is it proprietary to us or to one of our business partners or suppliers? My team and I just fi nished putting the fi nal touches on some special football packaging that will run with an exciting new ad campaign during football season. I have a prototype of the package and can t wait to show my friends at the barbecue on Saturday. They ll get the fi rst look and won t believe how creative it is! Would our company be disadvantaged or harmed if others knew this information? If I think the answer is yes to any of these, I treat the information as confidential and take the necessary steps to protect it.

13 13 Turn to next page for Do I (or anyone I have a close personal relationship with) hold an infl uential position in a competitor company or a company who does business with Molson Coors? Do I (or anyone I have a close personal relationship with) have an ownership interest in a competitor company or a company who does business with Molson Coors? Do I hold a public offi ce that may require me to handle issues of interest to Molson Coors? Is there anything that may cause me to act other than in the best interests of Molson Coors when making a business decision? If the answer is yes to any of these, I ask the Office of Ethics and Business Conduct for advice. Some of the things I consider when thinking about a possible conflict of interest are: Avoid Conflicts of Interest Interest and and act act in the the company s company s best interests Living Our Values The Code We have a responsibility to act in the best interests of our company and cannot compete with the company or take personal advantage of opportunities that come our way as a result of our connection to the company. Sometimes we may have a personal or financial stake in the outcome of a decision, as well as influence over that decision. Even if we feel it s in the best interest of the company, in this type of situation, a potential conflict of interest exists. A conflict of interest can arise from any situation, including a family or other close personal relationship, which might cause us to act, or appear to act, other than in the best interests of Molson Coors. It can be hard to sort out what is and is not a potential conflict of interest and how best to handle it. Because of that, we must discuss any such situation with our manager and our local Business Conduct Manager. Tell Me More Ethics and Compliance Helpline Ethics and Compliance Website More ways to connect our values to Conflicts of Interest

14 Living Our Values Avoid Conflicts of Interest and act in the company s best interests 14 I am on a team reviewing potential suppliers for a new promotion. No one else on the team knows it, but I am a silent partner in one of the suppliers who is bidding. After seeing all of the supplier presentations, I am convinced my company is the right supplier for this project; so I am just going to keep my mouth shut and see what the rest of the group thinks. Some of the things I consider when thinking about a possible conflict of interest are: Do I (or anyone I have a close personal relationship with) have an ownership interest in a competitor company or a company who does business with Molson Coors? Do I (or anyone I have a close personal relationship with) hold an infl uential position in a competitor company or a company who does business with Molson Coors? Do I hold a public offi ce that may require me to handle issues of interest to Molson Coors? Is there anything that may cause me to act other than in the best interests of Molson Coors when making a business decision? If the answer is yes to any of these, I ask the Offi ce of Ethics and Business Conduct for advice. Excelling When making supplier selections for a project, it may be easy to rely on your current relationships to make a selection. But, taking a hard look once in a while at those relationships may show that new approaches may be a better recipe for success. Passion Managers can show their commitment to the company and to their teams by acknowledging potential conflicts and then going through proper channels to handle it appropriately. Creativity Integrity & Respect Major suppliers often Raise issues early. invite employees to Ask others for their attend events, sometimes input. There are often with many perks creative solutions for associated that might dealing with potential create a perceived conflicts of interest. conflict of interest down the road. By checking with your boss and business conduct manager ahead of time, you can find a way to take advantage of a good business opportunity without creating the appearance of a conflict or a question about your personal integrity. Quality Being open and transparent about anything that may appear to cause you to act other than in the best interests of the company is the best way to make a quality decision.

15 Living Our Values Actively support our goals for Health, Safety and the Environment 15 The Code At Molson Coors, we want our employees to be healthy and safe. We believe reducing our impact upon the environment is not only good for the earth, but also good for the company. We comply with the laws... and often go beyond those standards. To achieve this, we implement enterprise-wide management systems based on internationally recognized standards that set EH & S standards and objectives, develop our employees to instill ownership of EH & S at all levels of the organization, and drive continual improvement. It makes me feel good to know that my company takes responsibility about the environment seriously. I do my part by turning off the lights when I leave a conference room and using the recycle bins located in the offi ce for disposing of recyclables. Turn to next page for Tell Me More Link to Corporate Responsibility Area of Website Global QHES Policy Ethics and Compliance Helpline More ways to connect our values to Health, Safety and the Environment Ethics and Compliance Website

16 Living Our Values Actively support our goals for Health, Safety and the Environment 16 Excelling We strive to be recognized for Corporate Responsibility which includes specific goals around health, safety and the environment. Look for ways you can contribute. Passion Are you passionate about safety? How often do you talk about the importance of safety in your work area? Integrity & Respect If you see someone else acting in an unsafe way, talk with them about it. Safety is everyone s business. Creativity Challenge yourself. What can you do to reduce your area s impact on the environment? Quality Employees deserve to go home the way they walked in that morning. Do you wear your safety equipment every day to help make sure that happens? It makes me feel good to know that my company takes responsibility about the environment seriously. I do my part by turning off the lights when I leave a conference room and using the recycle bins located in the offi ce for disposing of recyclables. As I was walking to my job, I noticed a strange liquid going down a drain. I didn t know what it could be, but I was running late and didn t have time to report it.

17 Living Our Values Know and follow the rules for Trading in Company Stock 17 The Code Even if we re not senior managers, each of us may know inside information about the company which is not known to the public and which, if known, could impact our stock price. It is important that we not buy or sell company stock if we have such information, or tell anyone else to buy or sell company stock as a result of this information. We must avoid even the appearance of violating these rules. If we trade the company s stock, we must be aware of timing restrictions on trading and comply with the Company s Insider Trading Policy. I recently got assigned to a special project that could be transformational for our business. I understand that until this project becomes public knowledge, I cannot trade in company stock, whether or not there is an open trading window. Turn to next page for Tell Me More Global Insider Trading Policy Ethics and Compliance Helpline Ethics and Compliance Website More ways to connect our values to Trading in Company Stock

18 Living Our Values Know and follow the rules for Trading in Company Stock 18 I recently got assigned to a special project that could be transformational for our business. I understand that until this project becomes public knowledge, I cannot trade in company stock, whether or not there is an open trading window. I was looking for some information on the company intranet and inadvertently came across profit and sales figures for the current quarter that had not yet been released. I can t wait to go home and tell my partner. Based on that performance, we can expect the price of the company s stock to increase and maybe we should buy some more shares before it does. Passion Excelling Make sure you are free of inside information and in an open trading window before trading in company stock. Don t let your passion outweigh your common sense. What you are working on may be very exciting, but not yet appropriate to share. Integrity & Respect Be careful what you say in social situations. You may accidently make your friends and family members an insider to material information (such as unannounced financials or big business deals). Creativity History has shown that this isn t a good area to think outside the box. Save your creativity for other areas. Quality Plan your trades wisely. Pay attention to the trading windows. Longterm tools, such as a 10B51 plan, can help enable you to sell stock regardless of events inside the company.

19 19 I know that some political issues, such as changes in excise taxes, can have a signifi cant impact on our company which is why I stay informed about them; however I would never engage in political activity on behalf of the company without fi rst checking with Public Affairs. Turn to next page for Living Our Values The Code Involvement in a political campaign or making a donation to a candidate is a personal decision which is respected by the company. However, we can never engage in political activity on behalf of the company without first checking with Public or Government Affairs. We also don t use company resources (such as the copier, phone or fax machine) to promote a candidate. Even giving the impression that the company is involved with the donation or campaign can send the wrong message. If we d like to be involved in political activities on behalf of Molson Coors, talk with the Public Affairs team or your Business Conduct Manager about appropriate ways to volunteer. More ways to connect our values to Political Contributions Get approval before before making making Political Political Contributions Contributions Tell Me Me More More Local Corporate Corporate Contributions and and Volunteer Activities Policies Policies Global Global Anti-bribery & & Corruption Policy Policy Ethics and and Compliance Compliance Helpline Helpline Ethics and and Compliance Website Website

20 Living Our Values Get approval before making Political Contributions Excelling 20 Be informed about political issues that may have an impact on our business (such as excise taxes, water issues or alcohol policy). Integrity & Respect Passion We can all be passionate about beer and about issues impacting the beer business. Work with Public Affairs on how best to channel your passion. When involved in political activities, make it very clear if you are involved as an individual or on behalf of the company. Creativity Find ways to educate your co-workers about issues that are important to the beer business without pressing your political opinions on them. Quality The quality of our work and our reputation could be hurt by inappropriate political involvement. I know that some political issues, such as changes in excise taxes, can have a signifi cant impact on our company which is why I stay informed about them; however I would never engage in political activity on behalf of the company without fi rst checking with Public Affairs. I have very strong political opinions and am very active in volunteering for campaigns. Sometimes I stay in the office at the end of the day so I can use my computer, printer and telephone on volunteer work to support my candidate.

21 21 Turn to next page for As a team leader it is important to me that everyone feels comfortable, so I strive to create an environment that is free of any kind of discrimination or harassment. More ways to connect our values to Respect and Equal Opportunity at Work Treat others others with with Respect Respect and and Equal Opportunity Opportunity at at Work Work Living Our Values The Code We want to work for a company where we are treated with respect, our differences are considered assets and everyone is committed to a common set of standards and values. That is exactly the kind of company Molson Coors aspires to be a place where everyone feels comfortable and able to challenge the expected. As a Molson Coors employee, we are expected to treat others with respect on the job, and comply with all applicable policies and equal opportunity laws, including those related to discrimination and harassment. Tell Me Me More More Local Discrimination & & Harassment Harassment Policies Policies Ethics and and Compliance Helpline Helpline Ethics and and Compliance Website Website

22 22 Living Our Values Treat others with Respect and Equal Opportunity at Work As a team leader it is important to me that everyone feels comfortable, so I strive to create an environment that is free of any kind of discrimination or harassment. One of my colleagues is constantly making sexual innuendos that make me uncomfortable. But, I don t want to seem uncool or too politically correct, so I just let it slide. Excelling Take time to mentor or get to know people that are different from you. Go above and beyond to understand the many different backgrounds we all come from. Passion Encourage ideas that are different from your own. The best new products, services or processes come from those discussions. Integrity & Respect Treating each person in the company with respect is something expected of every employee. That doesn t mean you have to agree all the time. In fact, challenging each other in a respectful way helps the company make better decisions. Creativity How can we think out of the box if we re all the same? Diversity can drive creativity. Help find ways to attract people of diverse backgrounds into our organization. Quality Everyone can help create an environment where each person feels comfortable and is free to do their best work.

23 Living Our Values Use Company Resources appropriately 23 The Code Wise use and protection of the company s resources just makes sense it keeps costs down and improves our bottom line. It s everyone s job to protect both tangible assets (such as laptops, equipment, products and tools) and intangible assets (such as trademarks, ideas, information and time). Appropriate personal use of telephones and computers is OK. But, always use your good judgment. Never use them for something that could be considered offensive, limit your use of these items and always keep the company s best interests in mind. I travel with my laptop a lot and understand that it s not just the computer that is valuable, it s the information on it as well. Because of this, I make sure I use a portable lock to secure it in hotel rooms or offsite meeting rooms if I can t take it with me. Turn to next page for Tell Me More Global Information Technology Use Policy More ways to connect our values to Company Resources Global Intellectual Property Policy Ethics and Compliance Helpline Ethics and Compliance Website

24 Living Our Values Use Company Resources appropriately 24 Integrity & Respect Quality Excelling Let s not give away what makes us great. Passion We ve invested millions in our brands iconic look. It s valuable intellectual property that we all must protect. Never think that we are entitled to something just because we work hard. Company property is well the company s property. Creativity Molson Coors always wants to support employees out of the box thinking. Just ask if you have an idea that involves using company resources: it might be OK. Being a champion and a safe keeper of the quality of our beers also means being a safe keeper of the company s resources. I travel with my laptop a lot and understand that it s not just the computer that is valuable, it s the information on it as well. Because of this, I make sure I use a portable lock to secure it in hotel rooms or offsite meeting rooms if I can t take it with me. I am so passionate about beer that I began home brewing. I routinely bring tools home from work to work on my equipment, but recently, I also took a small amount of yeast to go in my new lager recipe. I can t wait to see how the beer turns out!

25 Living Our Values Need to Ask a Question or Raise a Concern? 25 As a Molson Coors employee, you are responsible for understanding and following the Code and any laws or Company policies that apply to your job responsibilities. If you are not 100% sure what the right thing to do is, speak with your boss, your Human Resources representative or Ask a Question using the Ethics and Compliance Helpline. At Molson Coors, we believe that speaking up is the right way to demonstrate our values, build a culture of integrity and protect ourselves and the company from risks associated with non-compliance that could harm our reputation and continued success. We are all responsible for reporting anything we believe is or may be a violation of the Code so that it can be properly investigated. Raise a Concern using the Ethics and Compliance Helpline. The Ethics and Compliance Helpline is a central means of receiving confidential and anonymous questions and reports. Anonymous reporting through the Ethics and Compliance Helpline will be accepted to the extent allowed by the laws of your country. Retaliation by anyone against an employee for reporting a suspected violation of the Code is prohibited by law and company policy. Tell us a story about winning the right about winning the right way we d love to hear it, and we may use it in future publications of the Code! Tell Me More Global Speaking Up Policy Ethics and Compliance Website Call Ethics and Compliance Helpline The Small Print Molson Coors makes it a policy to comply with all laws and regulations applicable to its business. Each employee, offi cer and member of the Board of Directors is expected to conduct all activities related to, or refl ecting on, Molson Coors business with integrity and according to the letter, spirit and intent of all applicable laws and this Code of Business Conduct. References to you, we or employees throughout this Code include employees, offi cers and all members of the Board of Directors. Any employee who believes that a waiver of this Code is warranted should contact the Offi ce of Ethics and Business Conduct. However, a waiver of (or amendment to) the Code for offi cers or members of the Molson Coors Brewing Company (MCBC) Board of Directors may be made only by the MCBC Board of Directors or the MCBC Audit Committee and must promptly be disclosed to shareholders. Confi rmed violations of the Code can result in disciplinary action up to and including dismissal.