LIVINGOURVALUES
THE BROWN-FORMAN CODE OF CONDUCT2
LIVING OUR VALUES – INTEGRITY RESPECT TRUST TEAMWORK EXCELLENCE- ALCOHOL RESPONSIBILITY- HUMAN RIGHTS- ANTI-CORRUPTION- INSIDER TRADING

Reputational Risk / Alcohol Abuse

Books and Records / Third-Party Due Diligence /Facilitating Payments / Gifts- ANTI-HARASSMENT AND ANTI-DISCRIMINATIONDiversity / Fair Employment Practices / Abusive Conduct- COMMUNICATING ON BEHALF OF B-FMedia Inquiries / Social Media- COMMUNITY RELATIONSBuilding Goodwill / Professional Development-	COMPETITION AND ANTITRUSTFair Dealing / Improper Agreements /Competitive Intelligence- CONFLICTS OF INTEREST

Duty to Disclose / Outside Activities- CYBERSECURITY

Phishing / Network Access / Secure Passwords- ENVIRONMENT

Sustainability / Pollution Prevention- FINANCIAL INTEGRITY

Accurate Recordkeeping / Expense Reporting /Anti-Money Laundering- HEALTH, SAFETY, AND SECURITY

Injury Prevention / Workplace Violence Prevention

No Forced Labor / Third Party Due Diligence

Inside Information / Blackout Periods- INVESTIGATIONS

Duty to Speak Up! / Non-Retaliation- POLITICAL ACTIVITIESPersonal / Lobbying- PRIVACY

Personal Information / Data Breaches- PRODUCT QUALITY

Craftsmanship / Authenticity- PROTECTING ASSETS

Proprietary Information / Intellectual and Physical Property /Records Management-	RESPONSIBLE ADVERTISING AND MARKETING
Transparency / Marketing Guidelines- ROLE OF AN ETHICAL LEADER

Leading with Values / Safe Environment to Share Concerns- TRADE LAWS COMPLIANCE

Export Controls / Trade Embargoes / Economic Sanctions		- WORKING WITH SUPPLIERS AND BUSINESS PARTNERS
Due Diligence / Conflicts of Interest /Human Rights / Gifts

DIRECTORY OF RESOURCES

3

LIVING OUR VALUESAS WE STRIVE TO BE EVEN BOLDER AND
BETTER, WE STAND FIRMLY ON OURSTRONG ETHICAL FOUNDATION AND
LEAN INTO OUR CORE VALUES.

Now, more than ever, I am confident we are well positioned for
great success. Our portfolio of brands has expanded, we continue
to grow globally, and we are united in our shared commitment tothink bolder, to demand better, and to always live by our values.
With appreciation and respect,

The people of Brown-Forman, through their innovative thinking,diverse viewpoints, and commitment to our values, have helped
us to flourish since our founding in 1870. Today as we strive tobe even bolder and better, we stand firmly on our strong ethicalfoundation and lean into our core values of Integrity, Respect,
Trust, Teamwork, and Excellence.
I believe being part of Brown-Forman is both a tremendous
honor and immense responsibility. Each of us plays a role inupholding our culture of ethics—both now and in the future, andwith each interaction with colleagues, business partners, andstakeholders. We must always remember that how we do ourwork matters as much as what we do, and that by taking careof ourselves and each other, we will live up to our promise of“Nothing Better in the Market.”Lawson Whiting
Chief Executive Officer

4

LIVING OUR VALUES (CONT.)EVERYONE SHARES THE RESPONSIBILITYFOR ETHICAL LEADERSHIP AT
BROWN-FORMAN.
At Brown-Forman, we believe that everyone is an ethical leader by
ensuring that our values drive our decisions. Our ethical culture is ashared responsibility, and our commitment to this culture has led to
Brown-Forman being recognized as one of the World’s Most EthicalCompanies, three years in a row.
Brown-Forman operates in a complex business environment, where
it is important that each employee understands what is expected ofthem. Brown-Forman’s Code of Conduct translates our core values
into guidance that is relevant and important to any role. The Code of
Conduct is not only a document, but a toolkit of resources including
policies, procedures, training, and access to subject matter experts.
When you sign the Code of Conduct each year, you agree to:1) Comply with the Code of Conduct and referenced policies;
2) Report potential Code violations (“knot in the stomach”
situations); and
3) Willingly cooperate with an investigation of a Codeviolation.

Any waiver of the Code on behalf of an executive officer or a member ofthe Board of Directors must be approved by the Board, or a designatedBoard Committee and, under certain circumstances, disclosed in
documents filed with the Securities and Exchange Commission.
If you have a concern, please do not hesitate to share it. You can speakwith a manager, contact our Compliance Office, discuss it with Human
Resources, or anonymously report it through the Ethicspoint Hotline.
Brown-Forman forbids retaliation in any form when issues are raised ingood faith.
If you have a question regarding the Code of Conduct, my door is always
open. And if you have suggestions and ideas for improvement, pleaseshare them.
Thank you for your commitment to Brown-Forman,

Jerry Kral
Chief Risk, Ethics and Compliance Officer
Jerry_Kral@b-f.com

5

ALCOHOL RESPONSIBILITY

WHICH STATEMENT REFLECTS OURVALUES?

Our mission is to empower mindful choices around beveragealcohol. We strive to cultivate a responsible drinking culture
both inside and outside of Brown-Forman, and we’re“I know alcohol responsibility is important toBrown-Forman but, it’s not clear to me what I am
expected to do, so I just focus on my work.”proactive to ensure everyone feels welcome and has a positive“Although I’ve made a private and personal
decision not to drink, I feel respected by mycolleagues and business partners. At every
Brown- Forman event, there is an array of
alcohol-free drink options to choose from andno one ever asks why I’m not drinking alcohol.”take action to prevent alcohol-related harm. We do this byexperience with Brown-Forman and our brands. We model
responsible behaviors, abide by legal requirements, andengaging in initiatives such as the PAUSE Campaign, saferide programs, brand programs, the SPIRIT ERG, education
tools, and partnerships with organizations working on alcohol
responsibility.
As a Brown-Forman employee, you are a champion of
responsibility. When our values are put into action, it helps

LEARN MORE

ensure the long-term sustainability of Brown-Forman. If you

Brown-Forman.com/alcohol-responsibility

choose to consume or serve alcohol in any setting, whether

Bystander Intervention Panel Discussion

personal or business, you are expected to act responsibly. If

Employee Assistance Program (235)

you choose not to drink, we respect your choice. We encourage

Responsible Consumption and Service of Beverage Alcohol(400)

everyone to explore their unique relationship with alcohol andGlobal Alcohol Responsibility Website
Global Alcohol Responsibility Training

Contact Alcohol_Responsibility@b-f.com for more information.

to take advantage of the educational tools and support provided
through the SPIRIT ERG and other programs available throughour Employee Assistance Program (EAP).

6

ANTI-CORRUPTION

WHICH STATEMENT REFLECTS OURVALUES?
“My supervisor suggested offering the customs
official a free bottle of product to expedite thecustoms clearance process.”“When a container is stuck at the border, we
work with the customs officials to properly
complete the customs clearance process, even if
it means product is delayed and incurs storage
fees.”LEARN MORE
Anti-Corruption (605)
Gifts and Hospitality Involving Business Partners
and Government Officials (610)
Trade Laws Compliance (606)Travel, Entertainment and Related Expense (660)
Anti-Corruption Training
Ethics and Compliance Website

Contact our Chief Risk, Ethics and Compliance Officer for more information.

Our success is based on the quality of our products and the hard workof our people. We do not engage in bribery or other illegal or corrupt
behavior to advance our business. Each employee, officer, and director
must always strive to deal fairly with the Company’s customers,
suppliers, competitors, government officials, and employees. Noneshould take unfair advantage of anyone through manipulation,
concealment, abuse of privileged information, misrepresentationof material facts, or any other unfair-dealing practice. We follow thelaws of the countries where we operate, including import, export,
and customs laws, and if a local law or practice conflicts with our
Code or our policies, we always follow the stricter standard. Contact
Compliance if you are concerned that a payment could be improper.
Do not offer or accept anything of value in order to get business,
keep business, or gain a business advantage. Remember, a bribe
can be something other than cash – a gift, free product, meals or
entertainment, even a charitable contribution or job offer could beconsidered a bribe if it’s offered in exchange for favorable treatment.
If you’re not sure whether an offer is OK, check our policies or ask for
guidance before you make or accept it.
We are responsible for the actions of those who represent us, so makesure our business partners and suppliers don’t offer or accept bribes
either. Follow our due diligence procedures, and accurately record all
payments and expenses. Take care to avoid even the appearance ofimpropriety, and Speak Up if you see or suspect bribery or corruption,in any form.

7

ANTI-HARASSMENT AND
ANTI-DISCRIMINATION

WHICH STATEMENT REFLECTS OURVALUES?

We believe that diversity and inclusion make better, stronger,“My coworker was assigned to a special project
because he is single – my supervisor assumed hecould better handle the travel involved.”

more successful teams. We value and celebrate the unique“My supervisor invited me to work on a new project
team based on my past performance.”treated with fairness, dignity, and respect.

contribution that every person brings to Brown-Forman, andwe promote an open and inclusive culture where all people are

Give everyone an equal chance to succeed. Maintain zerotolerance for any form of abuse or harassment. And Speak Up

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about any breach of respect or any work-related decisions that

Equal Employment Opportunity (115)

are inconsistent with our values.

Hiring, Promotion and Employment Classification(105)
Discrimination, Sexual Harassment and Other
Harassment, and Retaliation Prevention (135)
Dignity and Respect in the Global Workplace

Contact our Equal Employment Opportunity Officer or Human Resources for more information.

8

COMMUNICATING ON BEHALF OF B-F

WHICH STATEMENT REFLECTS OURVALUES?
“If I see bad information posted on social media
about Brown-Forman, I always correct it. People
should hear from someone who works here.”“Whenever I speak about Brown-Forman onsocial media, I make it clear that my views are
my own.”We’re proud of the stellar reputation that generations ofBrown-Forman employees have built, and we work hardto preserve it. One inadvertent comment to the press, one
sarcastic blog post, one impulsive comment directed at aconsumer – all can have serious repercussions for BrownForman and the reputation we’ve worked so hard to earn. That’s
why we have designated individuals to serve as official BrownForman spokespersons.
Unless you are authorized to do so, don’t make any public

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Communications to Employees (405)Communications, Corporate Image and Logo
Use (410)

statements on behalf of Brown-Forman. Forward inquiries
to Corporate Communications to ensure that accurate andcomplete information is conveyed to the media, to the public, toregulatory authorities, and others.

Social Media (704)Statements to the Media (620)

Be responsible in your use of social media. Make sure that any
opinions you express are identified as your own, and not thoseof Brown-Forman. And don’t post anything that would violate
our policies, such as confidential information or the logos ofBrown-Forman or its affiliates.

Contact our Director of External Communications for more information.

9

COMMUNITY RELATIONS
Through volunteer engagement and charitable contributions, Brown-Forman

WHICH STATEMENT REFLECTS OURVALUES?

is committed to doing our part in the communities that share the places wecall home. This approach reinforces our culture of caring, builds goodwill forthe company and our brands, and provides valuable professional development
for our employees. Volunteerism benefits the community and provides team-“Our team has identified a local nonprofit we’d liketo support. I am going to schedule a mandatory
volunteer opportunity for the entire team.”building experiences for our employees.

“Our team has identified a local nonprofit we’d liketo support. I have created a volunteer opportunityin B-F Connect where teammates can sign up to
participate if they are interested and have time to doso.”volunteer project to ensure you follow the guidelines and provide participants

There are many ways to incorporate volunteering into your meetings andother activities. Utilize the resources linked under Learn More when planning awith a safe and meaningful experience. Volunteerism should not impact yourability to do your job or in any other way negatively impact the Company’s
interests.
Charitable contributions build brand equity and support Brown-Forman’s

LEARN MORE
Charitable Contributions Policy
Employee Volunteer Program Guidelines
Guide to Nonprofit Board Service
Product Donation Guidelines

business priorities. The Global Community Relations Team manages ourcharitable programs, to ensure visibility into all commitments and provide
oversight. Before contributing from your budget, ensure it meets the criteria bycarefully reviewing the Charitable Contributions Policy.
Only approved charitable organizations may receive a contribution. In addition,
the activity must comply with all applicable laws. All recipients of BrownForman charitable contributions must be either a 501(c)(3) organization (in theUS) or equivalent (outside of the US) or a public charity operated exclusively forcharitable, scientific, or educational purposes as described in the US tax code.
Under no circumstances should anything of value be offered or provided toany entity as a bribe, or in exchange for any improper business benefit to theCompany. Personal donations should never be charged to the Company.

Contact our Director of Global Community Relations for more information.

10

COMPETITION AND ANTITRUSTWHICH STATEMENT REFLECTS OURVALUES?
“When interviewing candidates who work forcompetitors, I try to get as much information
about pricing and costs as possible.”“A candidate I was interviewing tried to share acompetitor’s pricing strategies. I told her it was
proprietary and changed topics.”

We put our brands to the test in the marketplace and let our
superior products – not unethical practices – drive our success.
We follow competition and antitrust laws and compete fairly,
knowing that any conduct that limits (or even appears to limit)
competition can violate not only these laws, but our sense ofwhat’s right.
Don’t let a casual conversation with other industry players turn

LEARN MORE
Brown-Forman Europe Legal Website

into something improper or unlawful. Avoid any agreementswith competitors that could restrict competition. Make sure webid fairly in any competitive bidding situation. And, in gathering
information about our competitors, use only lawful and ethicalmethods and publicly available sources.

Contact our Antitrust Compliance Officer for more information.

11

CONFLICTS OF INTEREST

WHICH STATEMENT REFLECTS OURVALUES?
“My sister’s marketing agency needs new businessand I need help, so I am going to use her firm. It’s awin/win!”“We are running a selection process for a newmarketing agency and will choose the winner
based on objective criteria.”

LEARN MORE
Conflicts of Interest (600)
Conflicts of Interest Disclosure Form
Conflicts of Interest “Meeting in a Box”
Conflicts of Interest Toolkit

A conflict of interest arises when your personal interests
interfere with your Brown-Forman position or ability to makeobjective decisions on behalf of the Company. We work to avoid
even the appearance of a conflict.
Although the Conflicts of Interest Policy does not list every
situation that can present a conflict, there are a few instanceswhere conflicts typically arise:• Financial Interests - Investing in a company that does
business or competes with Brown-Forman.
• Business Opportunities - Taking opportunities for yourself
that are discovered through the use of corporate property,
information, or position.
• Outside Activities - Allowing service to another organization ora second job interfere with your obligations to Brown-Forman.
• Personal Relationships - Supervising a family member orsomeone with whom you have a romantic relationship.
Brown-Forman employees must promptly disclose all personal
interests that might reasonably be perceived as affecting their
judgment to perform their roles or may create an appearance ofimpropriety.

Contact our Chief Risk, Ethics and Compliance Officer for more information.

12

CYBERSECURITY

WHICH STATEMENT REFLECTS OURVALUES?
“There is a new AI tool that will help me organize
my meetings by summarizing meeting content.
It’s free so it’s okay for me to use.”“I got an email from my friend asking me to checkout a cool video. I clicked on it and it showed me
nothing. I realized I fell for a phish! I contacted the
IT Service Desk immediately and they were able tocontain the malware.”

We are good stewards of data and conscientious about data security,
ensuring our information and systems are protected from unauthorizedaccess, modification, or loss. The internet is filled with threats, fromphishing emails to malicious websites. Careless activities online can put
Brown-Forman at risk, so we err on the side of caution and contact IT
Security if we become aware of any suspicious activity.
Accepting terms and conditions of tools and software (especially without
reading them!) may lead to unintended consequences, such as agreements
for licensing and fees even when the tool is free or has a free trial.
Additionally, it may include an agreement to share or give up rights to datathat is collected by the tool, with Brown-Forman data being stored and usedin breach (contractual or regulatory) of Company obligations. In the case ofAI, Brown-Forman confidential data could be used to train the AI tool itself.

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Observe good cybersecurity practices. Keep your passwords updated

Corporate Mobile Device (720)and secure. Never open emails from unknown senders or emails that are

Data Incident Reporting (750)inconsistent in tone or subject matter, even if you believe the source. Don’t

Responsible Data Handling (740)
Data Privacy and Cyber Security Training

install unauthorized software, applications, hardware, or storage devices
on your Brown-Forman-issued device(s), and don’t conduct businessover unauthorized applications or devices. Immediately report to IT
Security any situation in which systems or data security may have been
compromised.

Contact our Chief Information Security Officer for more information.

13

ENVIRONMENT

WHICH STATEMENT REFLECTS OURVALUES?

Caring for natural resources and the climate isn’t simply a business concern
for us. From the fields that grow our grains and agave, to the water we“While visiting a customer, they shared
information about their new climate pledge. I
don’t know what Brown-Forman is working on, so
I decided not to prioritize a response.”transform into our spirits, to the oak for our barrels, we depend on the earth’s“I had an idea that by installing motion sensitive
lights we could help reduce our office carbon
footprint. I told my manager about it and followed
up with our office manager to install them. It’s asmall change, but it’s making a big difference.”

design to office design, from distilling our products to selling them, and frombounty. It’s about committing to the environment that sustains us, caring forthe resources we share with our community, and nurturing what we havefor those who come after us. We work diligently in all we do – from package

reducing waste to finding innovative ways to keep products and materials inuse.

Do your part to help us protect and conserve the natural resources we

LEARN MORE
Environmental Performance (685)Corporate Sustainability One Pager
Environmental Sustainability at Brown-Forman
Environmental Sustainability Google Site

Contact our Director of Global Environmental Sustainability for more information.

rely on. Comply with internal policies and procedures as well as local
environmental laws and regulations. Cooperate with officials charged with
enforcing regulations designed to protect and sustain our natural resourcesand environment. In addition to environmental compliance, help us achieve
our goals by integrating sustainability into your work practices, fromprocurement to marketing and beyond.

14

FINANCIAL INTEGRITY

WHICH STATEMENT REFLECTS OURVALUES?
“I have an unplanned invoice that probably should
be charged to Discounting, but with all the attention
on gross margin, I will just charge to Brand
Expense.”“When coding invoices, I charge the correct
category. If I am unsure, I seek guidance from myfinance colleagues.”

We manage our finances responsibly and rely on every employee– not just those in Accounting and Finance – to create andmaintain records that are accurate and complete. Financial
integrity ensures we meet our financial commitments andestablishes confidence in our systems and reporting. It enables
us to make good business decisions that impact each one of us
and drive Brown-Forman’s long-term success.
Be honest. Be transparent. Charge expenses to the proper

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category. Whether you’re coding an invoice, filling out an

Code of Ethics for Senior Financial Officers

expense report, or filing a financial statement or any other

Conflicts of Interest (600)“record,” follow our internal controls and comply with our

Ethical Financial Conduct (640)policies. Provide proper supporting documentation and obtain

Financial Authorization Guidelines

all necessary approvals. Be alert for any suspicious financial

Global Procurement (670)transactions to guard against crimes like fraud, embezzlement,

Petty Cash Funds (645)and money laundering. Check our Records Management Policy

Records Management (615)

to make sure information is stored, managed, and disposed ofTravel, Entertainment and Related Expense (660)properly.

Responsible Travel and Expense Management Training

Contact our Chief Accounting Officer for more information.

15

HEALTH, SAFETY, AND SECURITY

WHICH STATEMENT REFLECTS OURVALUES?
“If I’m in a meeting during an emergency drill, I
just continue with the meeting. I see no point incanceling my meeting when it is only a drill.”“I need to be prepared to respond appropriately
to protect myself and my team in the event of an
emergency. That includes performing preparation
drills and following response instructions.”

We recognize that our most important asset is our people. We
have policies and procedures in place designed to keep BrownForman injury-free, but a healthy and safe work environment
requires a team effort.
Observe safe work practices. Follow our policies and the law
to reduce risk and to keep Brown-Forman in compliance withhealth and safety regulations. Speak up about any potential
hazards, near misses, or injuries. If you should experience awork-related injury, please contact HR, Risk Management, or
the Health and Safety Team for guidance as soon as possible.

LEARN MORE
Health and Safety (415)Workplace Aggression (140)
Crisis Management Website
Workplace Violence Awareness–Active Shooter
Response Quick Reference
Workplace Violence: Awareness, Prevention andResponse Training

If you are unsure if something is risky, please contact Risk
Management.
Keep our workplace violence-free, too, by being alert to what
is going on around you and speaking up about any threats,
intimidation, behaviors of concern, or property damage. Follow
all security policies for your location, especially those that relate
to wearing your badge and escorting visitors.

Contact our Global Director of Corporate Health, Safety and Crisis Management or our Director of Global Security for more information.

16

HUMAN RIGHTS

WHICH STATEMENT REFLECTS OURVALUES?

At Brown-Forman, we respect and support human rights in our“I read in a news article that a Brown-Forman supplier
was accused of human rights violations. The story didn’t
mention Brown-Forman, so I assume I shouldn’t worry
about it.”Global Compact and are committed to operating in ways that

“We are engaging a new branded merchandise supplierwith manufacturing facilities in high-risk markets. To
better understand if there are concerns from a humanrights perspective, I reported the proposed engagement toCompliance, and together we conducted appropriate due
diligence before moving forward with the engagement.”

We value diversity and inclusion, and we strive to provide

workplace, in our relationships with business partners, andin our communities. We are a signatory to the United Nations
are consistent with fundamental responsibilities in the area of
human rights.

a healthy and safe workplace that is free from harassment,
discrimination, aggression, and all forms of forced labor.
Due diligence on proposed business partners helps us mitigate
human rights-related risk. We communicate our policies
and expectations to our suppliers via our Supplier Code of

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Conduct and pursue partnerships with those who share our

Global Human Rights (470)

commitment to respecting human rights.

Supplier Code of Conduct
Human Rights Panel Discussion

Remember that human rights risk is not limited to certain

Global Human Rights Training

countries or types of engagements. Each of us is responsible forreporting concerns if we suspect or become aware of potential
violations of human rights.

Contact our Chief Risk, Ethics and Compliance Officer for more information.

17

INSIDER TRADING

WHICH STATEMENT REFLECTS OURVALUES?
“I just saw an internal report that said our sales
were way up last month. It’s a good time for me tobuy shares of Brown-Forman.”“I keep inside information confidential, and I neverbuy or sell stock based on it.”We recognize that we often possess material nonpublic (“inside”)
information about Brown-Forman or companies with which we dobusiness; we never take advantage of that. We’re in a position of trust,so we never buy or sell Brown-Forman stock, or stock of a company
with which we do business, based on this information or “tip off”
others so they may trade. Insider trading is not only unfair and a
violation of our Code, it’s illegal.
Make sure you know what kind of information is considered inside
information and protect it. It can include news or information

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about a merger or acquisition, significant new products, businessCorporate Disclosure Policy

performance, earnings guidance, or other events that may impact

Insider Trading (590)

Brown-Forman’s stock price or the stock price of a company withRelated Person Transactions (595)which we do business.

Responsible Information and Insider Trading
Training

If you’re not sure if information is considered inside information, ask
before trading. If you’re not sure if information has been released
to the public, treat it as though it is still confidential. And if you aresubject to a trading window or blackout period, don’t trade until the
restriction has been lifted.

Contact our Securitues Law Compliance Officer for more information.

18

INVESTIGATIONSWHICH STATEMENT REFLECTS OURVALUES?
“A compliance investigator requested an interview
with me to go over the details of some recent
projects. I ignored the interview request and neverspoke to the investigator.”“I was approached by a compliance investigator toanswer questions about an ongoing investigation
related to one of my colleagues. I cooperated fullyand did not mention the investigation to anyone else
I worked with.”

LEARN MORE
Investigations Process Data
EthicsPoint Hotline
Speak Up Posters

Brown-Forman’s Code of Conduct certification requires
all employees to report any event, action, or conductthat may violate the Company’s Code, policies, or any
applicable law or regulation. Reports can be escalated
in any of the four manners shown on the Speak-Up!
graphic. Reports must be made in good faith, be factual,and contain as much detail as possible. Employees
and Managers may not independently investigate anallegation.
The Compliance Office will promptly review thereport and assign it to the appropriate investigatory
function. The investigation will be conducted under
the framework outlined in the Investigation Policy.
Employees must fully cooperate with the assigned
investigator and keep confidential all informationexchanged as part of the investigation. To the extent
possible, the investigator will take steps to keep
information related to the investigation confidential.
Brown-Forman forbids retaliation against anyone
who voices a concern related to a potential violationof the Code of Conduct or policy in good faith. Anyone
who engages in retaliation will face discipline, up to
and including termination, regardless of that person’s
position or stature within the Company.

Contact our Chief Risk, Ethics and Compliance Officer for more information.

19

POLITICAL ACTIVITIESWHICH STATEMENT REFLECTS OURVALUES?
“While at work, I am asking my colleagues todonate money to candidates from the politicalparty I support.”“At a recent school board meeting, the mayor
asked me about Brown-Forman’s position on acontroversial local tax proposal. I told her that I
was unable to speak on behalf of the company
and referred her to Brown-Forman’s Public
Affairs office.”

LEARN MORE
Political Engagements and Contributions (480)Social Media (704)
Political Involvement Training

Contact our Global Public Affairs Director for more information.

Brown-Forman recognizes that employees have personalviews and that there are sure to be differing politicalperspectives among employees. In the spirit of living ourcore value of “respect,” the best advice is for personal
discussion on political topics to occur on personal timeoutside the work environment.
We encourage employee involvement in theircommunities. We believe our employees’ politics are theirown choice and must remain separate from the work they
do for Brown-Forman. Brown-Forman’s political activity
is managed by Public Affairs, and only Public Affairs is
authorized to engage in any type of political activity on
behalf of Brown-Forman. In any of your civic or politicalactivities, ensure that you’re not giving the impressionthat your actions or opinions represent Brown-Forman.
If you decide to become a candidate for public office, talkto your manager to ensure that your political activities
will not impact your ability to do your job, and informthe Public Affairs office. Brown-Forman cannot fundyour political activity, either directly or indirectly, so
Brown-Forman will not reimburse you for expenses orcontributions to candidates. Additionally, using BrownForman’s resources, such as email, copiers, postage,or phones for political campaigning, regardless of thecandidate or issues involved, is prohibited by law. Laws
governing political activities are complex, so please reachout to Brown-Forman’s Public Affairs office for assistance.

20

PRIVACY

WHICH STATEMENT REFLECTS OURVALUES?
“When reaching out to our promotional
contractors, I send group emails. I put
transparency and efficiency over concerns forprivacy.”

We respect our consumers’, coworkers’, business partners’, andsuppliers’ legal right to and expectation of privacy—we handle
their personal information with care and in accordance withapplicable laws. We recognize the sensitivity of confidential
and personal information and the critical responsibility we“My sister is starting a new business and asked
for names and email addresses of attendees at a
recent promotion. I told her I couldn’t provide that
information.”

have to collect, store, use, share, and dispose of data (including
personal data) in a way that won’t put it at risk.
Know what kind of information is considered “personal
information.”* Use it in the way it’s supposed to be used, follow

LEARN MORE
Data Incident Reporting (750)
Employee Records and Employee Privacy (100)Records Management (615)
Responsible Data Handling (740)
Employee Privacy Notices
Data Privacy and Cyber Security Training

Contact our Privacy Officer for more information.

our data handling policies when handling it, and don’t share itwith anyone, inside or outside of Brown-Forman, who doesn’t
have a legitimate business need for it. Be aware that in order toshare data externally there must be a data sharing contract inplace. Be proactive. Report any suspected data breaches to thePrivacy Officer.
*Commonly referred to as PII, it can be as simple as someone’s name or as
technical as an IP address.

21

PRODUCT QUALITY

WHICH STATEMENT REFLECTS OURVALUES?
“I have so many deadlines to make, even if it puts
quality at risk, I’ve got to take this shortcut just to
get it all done.”“There may be an issue with one of the bottlingprocesses at my facility. I’ll let my supervisor
know right now, so it can be looked into.”

George Garvin Brown raised the bar in our industry when heintroduced the first bottled whiskey in 1870. That passion to
innovate and the drive to assure quality are at the core of who
we are as a company, and in the 150 years that followed, quality,
craftsmanship and authenticity have guided everything we do.
As Jack Daniel said, “Every day we make it, we make it the best
we can.” Do your part to make sure our brands meet or exceed
our internal standards as well as the standards set by laws,
regulations, and our industry. Be sure to monitor quality acrossour entire supply chain, too. If you become aware of anyone oranything compromising the integrity of our product, reportyour concerns immediately to your manager.

Contact our Global Director of Quality Assurance for more information.

22

PROTECTING ASSETS

We passionately protect all of the things that make us Brown-Forman.
The Company’s intellectual property (“IP”) assets (like trademarks,
copyrighted materials, and trade secrets), serve to give us a competitive

WHICH STATEMENT REFLECTS OURVALUES?

advantage in the marketplace. Failing to properly use and adequately“My cousin wants to use a modified version of
the Jack Daniel’s label as the logo of her new
restaurant. I told her that would be a great way toshow support for the brand.”are used in a proper manner and exclusively for legitimate business“My friend asked me for a jpeg of the Herraduralabel so he can sell personalized labels online. I
know our logos and labels are Brown-Forman’s
intellectual property, so I told him I could notprovide it. ”

protect these assets has a direct impact on the Company’s profitability
and threatens its competitive advantage. It is therefore incumbent on
all employees, officers, and directors to ensure the Company’s IP assets
purposes.
Remember that one breach, one misstep, one unfortunate choice—even if unintentional—can provide our competitors with an advantage,
harm our reputation, and erode the trust of our consumers andstakeholders. Please also remain vigilant to any external threats to ourbrands—including counterfeit products—and report them to the legal
department.
Employees, officers, and directors are required to maintain theconfidentiality of information entrusted to them by the Company or its

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Communications, Corporate Image and Logo Use (410)
Conflicts of Interest (600)
Data Incident Reporting (750)
Employee Records and Employee Privacy (100)
Hunting Counterfeits Video
Records Management (615)
Responsible Data Handling (740)
Data Privacy and Cyber Security Training

customers, except when disclosure is authorized or legally mandated.
Confidential information includes all nonpublic information that might
be of use to competitors, or harmful to the company or its customers, if
disclosed. Do not share confidential information with anyone outsideof Brown-Forman and only share with those inside Brown-Forman who
need to know.
Disposing of assets is just as important as keeping them safe. Check ourRecords Management Policy to make sure you’re storing, managing, anddisposing of information properly.

Contact our Chief Intellectual Property Compliance Officer or ethics@b-f.com for more information.

23

RESPONSIBLE ADVERTISING AND
MARKETING

WHICH STATEMENT REFLECTS OURVALUES?
“We’re sending an email newsletter to consumers
and we’d like to include a few photographs. I’m
assuming everyone depicted is of legal drinking
age, but I can’t really be sure.”“Before I send out any type of communication,
whether it’s for employees or consumers, I makesure anyone depicted in photographs is of legal
drinking age.”

We are committed to selling our products to adults of legal
drinking age in a manner that is both responsible andappropriate. To meet this commitment, we are fair, truthful,and transparent in our marketing and advertising, and wecomply with laws as well as industry guidelines and standards
in all countries where we do business when it comes to brandadvertising, consumer communications, promotional events,
packaging, labels, and distribution and sales materials.
If your job responsibility includes marketing or advertising ourbrands, follow both the letter and the spirit of our policies and

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all applicable guidelines. Be sure to seek help anytime you’reSocial Media (704)unsure about what’s required.

Brown-Forman Marketing Guidelines
Distilled Spirits Council (DISCUS) Code of
Responsible Practices for Beverage Alcohol
Advertising and Marketing

Contact our Trade Regulations and Marketing Practices Compliance Officer for more information.

24

ROLE OF AN ETHICAL LEADER

WHICH STATEMENT REFLECTS OURVALUES?
“I know I should give a ‘That’s The Spirit’ award to a direct
report who discovered some irregularities on a recent
invoice. Unfortunately, I have tight deadlines and I can’t
spare the time to fill out the award form.”“One of my direct reports asked to speak with me aboutsome bullying behavior she witnessed at a recent meeting. I
created a safe environment for her to express her concerns
and together we approached our Human Resourcesbusiness partner with the issue.”

At Brown-Forman, we believe that everyone is an ethicalleader by ensuring that our values drive our decisions. We
expect all employees, regardless of position, to be familiar with
our Code of Conduct and live Brown-Forman’s core values.
As ethical leaders, we create a safe environment for anyone
sharing a compliance concern and recognize colleagues who
demonstrate our values in action.
For leaders of people, there are additional expectations tomodel and champion Brown-Forman’s core values and create
an ethical culture for your team. Create an open reporting
environment and encourage “speaking up” where concerns are

LEARN MORE
Leader’s Toolkit
Speak Up Posters
That’s The Spirit Award Submission
Global Procurement (670)
Inclusive and Ethical Leadership Training
EthicsPoint Hotline

Contact our Chief Risk, Ethics and Compliance Officer for more information.

respected and properly reported without retaliation. Finally,
communicate with your team about compliance issues andpromote training opportunities.
Ethical behavior is everyone’s responsibility.

25

TRADE LAWS COMPLIANCE

WHICH STATEMENT REFLECTS OURVALUES?
“A distributor shared that it is selling Brown-Forman
products into a sanctioned country, but this distributor
is one of my top accounts and is helping us meet our
financial targets, so it’s okay.”“When I engage in transactions on behalf of BrownForman, I make sure that we consider all export
requirements, verify the customer is legitimate, andensure all government all licensing requirements are
met before we do business.”

LEARN MORE
Trade Laws Compliance (606)Trade Laws Training
Invoice Review Training

Our products are enjoyed in more than 170 markets
around the globe, and we comply with applicable laws andregulations governing international trade. We follow the lawsof the countries where we operate, including import/export
regulations, trade sanctions, and anti-money laundering laws.
We do not conduct unauthorized business with countries or
persons that are subject to trade embargoes, or economic ortrade sanctions. We do not participate in boycotts, and we donot violate applicable export controls. Please consult our Trade

Laws Compliance Policy for more information.
We are responsible for preventing actions or activities
designed to disguise the origins of money. If you are concernedthat a transaction serves no apparent business purpose,
involves funds derived from illegal activities, or is designed toevade regulations, please immediately report your concern toCompliance.

Contact our Chief Risk, Ethics and Compliance Officer for more information.

26

WORKING WITH SUPPLIERS AND BUSINESS PARTNERS

WHICH STATEMENT REFLECTS OURVALUES?
“Once I conduct my due diligence in selecting a supplieror business partner, I rest assured and never botherchecking to see if anything may have changed.”“I do my best to choose suppliers and business partners
that share our values. Then I monitor them to ensure they
live up to their reputation.”

LEARN MORE
Conflicts of Interest (600)Gifts and Hospitality Involving Business Partners andGovernment Officials (610)

We recognize that ethical partnerships – ones built on trust,transparency, and mutual respect – are a key part of our
success. So we choose business partners and suppliers whomeet their contractual obligations, honor our values, andmaintain high business standards. Brown-Forman can beheld responsible for the actions of its business partners andsuppliers, so it’s critical to know who we are engaging withand for what purpose.
Source responsibly. Make decisions based on objective
factors like quality, price, and reliability, and do so in atransparent manner.

Global Human Rights (470)

Be especially alert to potential conflicts of interest, humanGlobal Procurement (670)

rights abuses, and acts of bribery and corruption – any

Supplier Code of Conduct

conduct that reflects poorly on our partners, reflects poorly

Travel, Entertainment and Related Expense (660)

on us. Report all potential conflicts immediately.

Contact our Chief Risk, Ethics and Compliance Officer for more information.

27

DIRECTORY OF RESOURCESPOLICIES, PROCEDURES, GUIDES ANDWEBSITES
Anti-Corruption (605)
Brown-Forman.com/alcohol-responsibility
Brown-Forman.com/enviromentalsustainability
Brown-Forman Europe Legal Website
Brown-Forman Marketing Guidelines
Charitable Contributions Policy
Code of Ethics for Senior Financial Officers
Communications, Corporate Image andLogo Use (410)Communications to Employees (405)
Conflicts of Interest (600)
Conflicts of Interest Disclosure Form
Conflicts of Interest “Meeting in a Box”
Conflicts of Interest Toolkit
Corporate Disclosure Policy
Corporate Mobile Device (720)Corporate Sustainability One Pager
Crisis Management Website

Data Incident Reporting (750)Discrimination, Sexual Harassment
and Other Harassment, and Retaliation
Prevention (135)
Distilled Spirits Council (DISCUS) Code of
Responsible Practices for Beverage Alcohol
Advertising and Marketing

Health and Safety (415)
Hiring, Promotion and Employment
Classification (105)

Employee Assistance Program (235)
Employee Privacy Notices
Employee Records and Employee Privacy(100)
Employee Volunteer Program Guidelines
Environmental Performance (685)
Environmental Sustainability Google Site
Equal Employment Opportunity (115)
Ethical Financial Conduct (640)
Ethics & Compliance Website
EthicsPoint Hotline

Leader’s Toolkit

Financial Authorization Guidelines
Gifts and Hospitality Involving Business
Partners and Government Officials (610)
Global Alcohol Responsibility Website
Global Human Rights (470)
Global Procurement (670)
Guide to Nonprofit Board Service

Insider Trading (590)
Investigations Process Data

Petty Cash Funds (645)Political Engagements and Contributions(480)
Product Donation Guidelines
Records Management (615)
Related Person Transactions (595)
Responsible Consumption and Service ofBeverage Alcohol (400)
Responsible Data Handling (740)Social Media (704)
Speak Up Posters
Statements to the Media (620)Supplier Code of Conduct

28

DIRECTORY OF RESOURCESPOLICIES, PROCEDURES, GUIDES ANDWEBSITES (CONT.)
That’s The Spirit Award
Trade Laws Compliance (606)Travel, Entertainment and RelatedExpense (660)Workplace Aggression (140)
Workplace Violence Awareness–Active
Shooter Response Quick Reference

TRAININGCONTACTS

Anti-Corruption Training

Alcohol_Responsibility@b-f.com
Antitrust Compliance Officer

Bystander Intervention Panel Discussion
Data Privacy and Cyber Security Training
Dignity and Respect in the Global
Workplace
Global Alcohol Responsibility Training
Global Human Rights Training
Hunting Counterfeits Video
Human Rights Panel Discussion
Inclusive and Ethical Leadership Training
Invoice Review Training
Political Involvement Training
Responsible Information and Insider
Trading Training
Responsible Travel and Expense
Management Training
Trade Laws Training
Workplace Violence: Awareness,
Prevention and Response Training

Chief Accounting Officer
Chief Information Security Officer
Chief Risk, Ethics and Compliance Officer
Director of External Communications
Director of Global Community Relations
Director of Global Environmental
Sustainability
Director of Global Security
Equal Employment Opportunity
Compliance Officer
Global Director of Corporate Health, Safety
and Crisis Management
Global Director of Quality Assurance
Global Public Affairs Director
Human Resources
Chief Intellectual Property Compliance
OfficerPrivacy Officer
Securities Law Compliance Officer
Trade Regulations and Marketing Practices
Compliance Officer

29

TALK
to yourLine Manager

ENGAGE
with Jerry Kral
directly by phone
at +1-502-774-7839
or email at
ethics@b-f.com

CONTACT
EthicsPoint toshare your concern
anonymously byphone or email

SPEAK
UP!

REACH OUT
to HR, Internal Audit or
any Senior Leader

Brown-Forman prohibits retaliation against employees who reportacts inconsistent with our core values and Code of Conduct.