PMI 14-C
GLOBAL ANTI-CORRUPTIONPOLICY
Policy Approver & Accountable Senior Leader:
Policy Owner:
Last Updated:
Version:Senior Vice President & General Counsel, PMI
Vice President, Associate General Counsel, & Chief Compliance Officer, PMI
21 May 2024
2024.1

1. PURPOSE
This Policy sets forth the commitment of Philip MorrisInternational and all of its subsidiaries and affiliates(together “PMI”) to prevent and detect bribery andcorruption and to comply with all applicable anti-bribery
and anti-corruption laws, including the U.S. Foreign
Corrupt Practices Act (“FCPA”), and establishes thebasic principles and requirements for our interactions
with third parties, Government Officials andGovernment Instrumentalities.

4. PRINCIPLES•Integrity. We are committed to doing
business with integrity and complying
with applicable legal and ethicalstandards.

•Legitimate Purpose. Everything we domust be done with a clear and legitimate
intent and business purpose, without
hidden agenda or ulterior motive.

•Reasonable and appropriate. Everything
we give or provide should be customary,reasonable and appropriate in value andappearance, and never offensive.

•Transparency. All transactions andinteractions must be transparent, and theCompany’s books and records must beaccurate.

2. APPLICABILITY
This Policy must be followed by all employees andofficers of PMI, as well as PMI agents and third parties
when acting on behalf of PMI.

3. POLICY STATEMENT
Bribery and corruption of any kind are prohibited.
We never give or promise to give anything of value
to induce anyone to give us an improper benefit or toimproperly influence anyone’s decision.

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GLOBAL ANTI-CORRUPTION POLICY
5. REQUIREMENTS
5.1. Gifts, Travel, and Hospitality
Gifts, Travel and Hospitality are well-establishedbusiness practices. When used appropriately, Gifts,
Travel and Hospitality can help strengthen existing
relationships, foster new opportunities, and convey
respect and appreciation for stakeholders, including
Government Officials, Private Individuals, and otherthird parties. However, Gifts, Travel and Hospitality,
especially when given to Government Officials, canpose corruption risks and therefore require careful
review to ensure consistency with the law and ourstandards of conduct.

Gifts, Travel and Hospitality must always
be provided with clear intent, and must bereasonable, appropriate, infrequent andtransparent.

•Clear Intent. Gifts, Travel and Hospitality must
be intended for legitimate business purposes, andnever to bribe or unduly influence.

•Reasonable. Only customary and generally accepted
Gifts, Travel and Hospitality are permitted. Gifts
should only ever be modest tokens of appreciation
or recognition.

•Appropriate. Any Gifts, Travel or Hospitality must
be appropriate under the circumstances, and notcause offense or be perceived as improper. Cash,cash-equivalents, cash-equivalent gift cards, luxury
items, as well as anything that could be perceived
as offensive, sexual in nature or otherwise
inappropriate, are prohibited.

••

Infrequent. Gifts, Travel and Hospitality should
only be provided infrequently, up to 2 to 4 times
per calendar year, Gifts for special occasions orholidays, an occasional meal with a business partner,
or Travel & Hospitality in the context of necessary
business meetings and activities, are consideredinfrequent.
Transparent. Anything that we provide should bedone directly, openly and not hidden and mustbe accurately recorded and documented in theCompany’s books and records.
See the Gift, Travel and Hospitality Standard for
additional rules and processes, including documentationand pre-approval requirements, that must be followed
before engaging in these activities.
5.2 Offers of Employment, Fee-for-Service Agreements,& Contracts with Government Instrumentalities andGovernment Officials
Employing, retaining or contracting with consultants,
Healthcare Professionals, Healthcare Organizations,
Government Instrumentalities or Government Officials
can provide PMI with unique insights and opportunities.
However, contracting and paying Government
Instrumentalities, Government Officials, Former
Government Officials (or any of their close relatives)
can pose corruption risks and requires careful review
to ensure consistency with the law and our standards ofconduct.
A person or entity may only be hired fora legitimate need, at fair market value,transparently and based on documented
qualifications.
•Legitimate need. There must be a real anddocumented need to hire an individual (or contractwith an entity) with the expectation that they
perform a service or deliver an outcome that islegitimate and expected to add value to PMI.

•Fair market value. Payments must not be excessive
and must be in line with prevailing market rates
for similar services, deliverables and employment
arrangements.

•Transparent. All engagements must be documented
in an agreement that sets forth the commercial
terms, role, expected outcomes and/or deliverables,
and all required disclosures must be made toemployers, the public and/or other oversight bodies,PMI 14-C
GLOBAL ANTI-CORRUPTION POLICY
Contributions that are typically given in the market
and proportionate to the intent; they must not cause
offense or controversy and must align with theinterests of PMI.

as applicable.
•Qualifications. Any person or entity hired orretained must have the necessary qualifications andexperience to perform the task.

See the Employment and Fee-for-Service Standard for
additional rules and processes, including documentationand pre-approval requirements, that must be followed
before hiring or retaining a Government Instrumentality
or a current or former Government Official (including
their close relatives).
5.3 Grants, Donations, Sponsorships, Memberships andPolitical Contributions
Grants, donations, sponsorships, memberships andpolitical contributions (together “Contributions”) can belegitimate ways for PMI to support specific principles andpolicies and to demonstrate our commitment to being anactive and supportive member of our industry and thecommunities we serve. On the other hand, Contributions
can pose corruption risks and must never be made inorder to improperly achieve any business objective.

Contributions (including monetary or in-kind
items or services) may only be made withclear intent to legitimate organizations, andthey must be appropriate and transparent.

•••

Clear Intent. Contributions must be intended fortheir stated purpose without ulterior motive andnever to bribe or unduly influence the recipient or
any associated person.
Legitimate Organizations are properly establishedorganizations with a clear purpose and good
governance that are legally able to receive
contributions from PMI, such as industry
associations or non-profits that fulfill a social,charitable, economic or political purpose.
Appropriate. Contributions must be of a size
and nature that are comparable to other similar•

Transparent. Contributions must be made openly
and be monitorable and traceable to the final
recipients, and all required disclosures must be
made to the public and/or oversight bodies, asapplicable.

See PMI’s Social Contributions Policy (PMI 12-C) for
additional rules and processes, including documentationand pre-approval requirements, that must be followed
before making any Social Contributions, and see
the Contributions Standard for additional rules andprocesses, including documentation and pre-approvalrequirements, that must be followed before making anyother types of Contributions.
5.4 Third Parties who Interact with Government Officials
on PMI’s Behalf
Occasionally, PMI may have a business need to directly or
indirectly engage agents, distributors, local partners orother third parties to interact with Government Officials
and Government Instrumentalities on our behalf or forour benefit (“Business Intermediaries”). Since the actionsof Business Intermediaries can be attributed to PMI, theirengagements require careful review and oversight toensure consistency with the law and our standards.
Business Intermediaries must act in accordance with ourpolicies and standards and in compliance with all legaland regulatory requirements, including anti­-bribery laws.
•Due diligence. Relevant information about theownership, management, reputation, experience,reliability and potential legal and compliance risksof the Business Intermediary must be collected andevaluated.

•Legitimate need. There must be a real anddocumented need to hire a Business Intermediary
who is expected to add value to PMI.

•Fair market value. Payments must not be excessive
and must be in line with prevailing market rates for

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GLOBAL ANTI-CORRUPTION POLICY
similar services and engagements.
•Mitigating and Monitoring Measures. PMI mustensure that appropriate measures are put in place
before the engagement starts, to manage andmitigate any risk, and monitor the relationship.

•PMI will conduct compliance due diligenceon Business Intermediaries and will only
engage them when there is a legitimate
need, payments are fair market value andmitigating and monitoring measures are inplace to address risks.

See the Business Intermediary and Due DiligenceStandard for additional rules and processes, including
documentation and pre-approval requirements, thatmust be followed before engaging with PMI’s Business
Intermediaries.
5.5 Mergers & Acquisitions (M&A)
PMI may from time-to-time acquire full or partial equity
ownership in entities, which may make PMI liable for thenon-compliance or legal exposures of target entities.

To protect PMI, legal & compliance due
diligence must be conducted on all M&A
target entities.

•Due diligence. Relevant information about theownership, management, reputation, experience,
reliability and potential legal and compliance risksof the target entity, as well as their complianceprogram, must be collected and evaluated.

See the M&A Legal & Compliance Due Diligence Standard
for additional rules and processes that must be followed
for conducting compliance due diligence on target
entities.

5.6 Facilitating Payments
Facilitating payments are small payments, in cash or inkind, to a Government Official to expedite an action theGovernment Official should routinely take, which does
not require discretion and to which we are entitled.
PMI does not offer or make facilitating
payments.

If a Government Official requests a facilitating payment,
you must not make it and must clearly refuse it, even
if there will be negative business consequences.
Compliance must be informed as soon as possible about
requests for facilitating payments.
The rule against facilitating payments does not apply if apayment is made to protect against threatened imminent
physical harm that can reasonably only be avoided
through a payment. Compliance must be informed assoon as possible about personal safety payments.
5.7 Books & Records
All payments and expenses must be accurately
documented and recorded, including expenses
incurred in connection with Gifts, Hospitality, Travel,Contributions, Fee-for-Service engagements andpayments to third parties hired to interact on our behalf
with Government Officials.

PMI’s books and records must accurately andfairly reflect all transactions.

6. EXCEPTIONSGenerally, exceptions to this Policy will not be granted.
Only the PMI Chief Compliance Officer may grant
exceptions to this Policy.
Exceptions will only be granted in cases where thewording of this Policy may lead to an unintended
outcome for a case or scenario that has not been
anticipated, such that future versions of this Policy will bePMI 14-CGLOBAL ANTI-CORRUPTION POLICY
amended to accommodate the exception.

7. COMPLIANCE & SPEAKING UP
Violations of this Policy may lead to legal or disciplinary
action against those involved, including termination ofemployment.
PMI employees may also ask questions, raise concerns,
or, report instances of observed or suspected
misconduct, including non-compliance with this Policyor related Standards, by contacting any of the following:•Your supervisor, department head, or affiliate orfunction leadership;•Your PMI Compliance team key contact;•The PMI Compliance team confidential email
address at PMI.EthicsandCompliance@pmi.com; or•The PMI Compliance Help Line, which is a thirdparty operated reporting channel available 24 hours
a day, seven days a week, in all languages spoken at
PMI. You can contact the Help Line online at www.
compliance-speakup.pmi.com or by telephone at +1
303-623-0588. You many use the PMI ComplianceHelp Line anonymously, subject to local laws andregulations.

The Company does not tolerate retaliation against
employees who speak up in good faith about asuspected compliance violation or cooperate with aninvestigation.
See PMI’s Global Speaking Up Policy (PMI 16-C) for moreinformation.

8. RELATED INFORMATION
Policy Documents:•PMI Code of Conduct•

Gifts, Travel and Hospitality Standard•

Employment and Fee-for-Service Standard•

Contributions Standard•

Business Intermediary and Due Diligence Standard•

M&A Legal & Compliance Due Diligence Standard

Forms, Hyperlinks, and Other Attachments:•PMI Global Anti-Corruption Intranet Site•

Compliance Disclosures & Approvals in MyPMI

9. DEFINITIONSGift – anything of value (other than Hospitality, Traveland Contributions) that you provide to, or receive from,a third party not as a result of a legal or contractual
obligation.
Government Instrumentality – Includes: (1) any
government agency, department or subdivision,
including a legislature, administrative body, court, andministry, at the supranational, national, state and local
level; (2) any organization that serves a public purpose
and is closely tied to any level of government, but may
not itself be considered a government agency, including
government­owned or controlled universities, hospitals
and commercial enterprises; and (3) public internationalorganizations whose members are governments orGovernment Instrumentalities, such as the World HealthOrganization and the United Nations. For purposes ofthis Policy, an entity shall be considered government­
owned or controlled if a government (i) owns or controls
50% or more of the entity’s shares, (ii) funds more than
50% of the entity’s budget, or (iii) can otherwise direct
the management, policies or affairs of that entity.
Government Official – any officer, employee, or person
employed by or acting on behalf of any GovernmentInstrumentality, or any officials of a political partyor candidates for political office. Note that in somecontexts, as indicated in this Policy, interactions withclose relatives of a Government Official may be treatedas an interaction with that Government Official.
Former Government Official – a Private Individual whoin the preceding 12 months was a Government Official.
Healthcare Organization (HCO) – means any healthcare
or medical association or organization such as aPMI 14-C
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hospital, clinic, foundation, university or other teaching
institution or learned society, or any other entity
through which HCPs provide services. HCOs may beowned, operated, majority-funded or controlled by agovernment or Government Instrumentality, in whichcase the HCO should be treated as a Government
Instrumentality for purposes of this Policy.

Hospitality – drinks, meals and events such as concerts
or sporting events that are attended with a third party
and that are provided to, or received from, that thirdparty not as a result of a legal or contractual obligation.

Healthcare Professional (HCP) – means any member ofthe medical, dental, pharmacy or nursing professions
or any other person who in the course of his or her
professional activities may prescribe, recommend,purchase, supply, sell or administer a pharmaceuticalproduct. An HCP may be fully or partially employed by aGovernment Instrumentality, such as a public university
or public hospital, in which case the HCP should betreated as a Government Official for purposes of thisPolicy.

Travel – air travel, ground transportation, hotel, lodging,visa costs, food & drink, meals and hospitality, etc.
related to a trip.

Private Individuals – individuals who are not
Government Officials.