LABOUR & HUMAN RIGHTS POLICY

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1 LABOUR & HUMAN RIGHTS

2 1 CARLSBERG LABOUR & HUMAN RIGHTS CONTENTS 1.0 Non-discrimination 2.0 Forced labour 3.0 Child labour 4.0 Freedom of association and collective bargaining 5.0 Harassment 6.0 Working hours, benefits and wages 7.0 Leave 8.0 Employee contracts / letters Our employees are of great value to us and are the key to our success. The Carlsberg Group shall strive to establish a workplace where our employees can develop their potential in an open and inspirational working environment. We shall maintain a strong commitment to high standards for a fair, respectable and safe workplace for all employees in the Carlsberg Group. The Carlsberg Group shall respect international human rights principles and international labour standards. We shall support the United Nations Universal Declaration of Human Rights and the International Labour Organisation s Declaration on Fundamental Principles and Rights at Work. The Policy addresses following headings: 1. Non-discrimination 2. Forced labour 3. Child labour 4. Freedom of association and collective bargaining 5. Harassment 6. Working hours, benefits and wages 7. Leave 8. Employee contracts / letters Jørgen Buhl Rasmussen President & CEO Anne-Marie Skov Vice-President Group Communication, Chair CSR Steering Committee

3 LABOUR & HUMAN RIGHTS NON- DISCRIMINATION 1.1 We shall not accept any form of discrimination against our employees based on race, colour, gender, language, religion, political or other opinion, caste, national or social origin, property, birth, union affiliation, sexual orientation, health status, age, disability, or other distinguishing characteristics. Any employment-related decisions, from hiring to termination and retirement, shall be based only on relevant and objective criteria. FORCED LABOUR 2.1 The Carlsberg Group shall prohibit any form of forced labour, including bonded labour, indentured labour, slave labour, or human trafficking. Workers shall be allowed to move around freely and leave their place of work when their shift ends. CHILD LABOUR 3.1 The Carlsberg Group shall not condone the hiring of child labour under any circumstances. The minimum age for full-time employment shall be 15 or the legal minimum age for employment, whichever is greater.if the local minimum working age is 14 in accordance with exceptions for developing countries, this lower age shall apply. The Carlsberg Group shall refrain from hiring workers under the age of 18 for positions that require hazardous work that could jeopardise their health, safety or morals. FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING 4.1 The Carlsberg Group shall respect employees rights to form, join or not join a labour union or other organisation of their choice, and to bargain collectively in support of their mutual interests without fear of punitive actions such as intimidation, harassment or termination of employment. If no legally recognised union exists in the area of operations, or if only state-authorised organisations are allowed, the Carlsberg Group shall respond favourably to initiatives to establish alternative means to achieving effective representation of worker s interest. HARASSMENT 5.1 Carlsberg Group companies shall protect workers from any acts of physical, verbal, sexual or psychological harassment, abuse or threats in the workplace by either their fellow workers or their managers. WORKING HOURS BENEFITS AND WAGES 6.1 The Carlsberg Group shall ensure that we adhere to all applicable laws or industry standards, whichever may be more stringent, relating to wages, working hours, overtime and benefits. Employees shall not be required to work more than 60 hours a week, including overtime, on a regular basis (or the limits on regular hours and overtime allowed by local laws and regulations). Wages for overtime shall be paid in legal tender on a regular basis. Wage deductions as a disciplinary measure shall not be permitted unless provided for by national law. Employees shall be entitled to at least one day off in seven, and shall be given reasonable breaks while working and sufficient rest periods between shifts. The Carlsberg Group shall be committed to continuously developing employee skillsand capabilities, and to providing opportunities for career advancement. In the event of major layoffs, the Carlsberg Group shall meet or exceed applicable laws and industry standards. LEAVE 7.1 The Carlsberg Group shall grant all employees the right to sick leave and annual holiday, as well as parental leave for employees who have to care for a newborn or newly adopted child as provided by national legislation. Employees who take such leave shall not face dismissal or threat of dismissal, and shall be able to return to their former employment at the same rate of pay and with the same benefits EMPLOYEE CONTRACTS / LETTERS 8.1 All Carlsberg Group employees shall be provided with a written, understandable and legally binding labour contract/letter. The Carlsberg Group shall not rely on part-time, short-term or casual labourers, trainees or false apprenticeships to pay lower wages and offer fewer benefits.

4 4 CARLSBERG GROUP SCOPE The Carlsberg Group Labour Rights Policy shall apply to all employees at Carlsberg Group subsidiaries, including workers who are engaged informally, on short-term contracts or on a part-time basis. Our joint ventures and business partners are strongly encouraged to adopt and implement our Policy. We require all our suppliers and licensees to comply with the Supplier and Licensee Code of Conduct, which sets out our social, environmental and ethical standards. Our subsidiaries are defined as companies Carlsberg Breweries A/S directly or indirectly owns or controls more than 50% of the voting rights in the subsidiary or which it, in some other way, controls. COMPLIANCE All subsidiaries within the Carlsberg Group shall comply with the provisions of the Labour Rights Policy as well as with national laws and regulations. Should there be differences between the content of this policy and national laws or other applicable standards, the more stringent requirements shall apply. Conflicts between the provisions of this policy and national laws or other applicable standards shall be evaluated by the Carlsberg Group Headquarters in cooperation with the Group companies. Companies that have recently joined the Carlsberg Group may be granted exemption from the policy s provisions during the integration period. APPLICATION Carlsberg Group subsidiaries shall implement the Labour Rights Policy in their daily work. All Group companies shall take appropriate action to ensure that the provisions of this policy are communicated to their employees in their own language. Compliance with policies, guidelines and codes shall be regularly tracked, and relevant corrective action plans identified and implemented. The Labour and Human Rights Policy is supported by Labour and Human Rights Guidelines which is an integral part of the Policy. Valid for: Carlsberg Group subsidiaries Approved by: Executive Committee Document type: Policy level 1 Reference: Group CSR Policies Version: 001 Approval date: The Carlsberg Group shall periodically review the Labour and Human Rights Policy and Guidelines in order to ensure its continued adequacy and relevance for our business. The most recent version will always apply.

5 Carlsberg Group 100 Ny Carlsberg Vej 1799 Copenhagen V Denmark Phone Fax

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