The Asahi Group’s Policy and Procedures for
the Marketing of Breast-Milk Substitutes (hereinafter, “BMS”)
Table of contents
1. Introduction—The Asahi Group’s Ideas for the Marketing of BMS—
2. The Asahi Group’s Marketing Policy for BMS
3. The Asahi Group’s Implementation Procedures for the Marketing of BMS
4. Annex

Introduction—The Asahi Group’s Ideas for the Marketing of BMS—The Asahi Group strives to achieve its aspiration of contributing to the healthy growth of
infants and young children based on the understanding of the importance of theInternational Code of Marketing of Breast-milk Substitutes from the World HealthOrganization (hereinafter, “WHO”) (hereinafter, the “WHO Code”) and the Resolutions
on Infant and Young Child Feeding adopted at the World Health Assembly (hereinafter,“WHA”).
The Asahi Group supports the sound and healthy growth and development of infants
and young children by protecting, promoting, and supporting breastfeeding and theprovision of safe, appropriate, and adequate nutritional supplement to infants andyoung children, and makes efforts to contribute to the realization of a sustainable
society.
The Asahi Group gives support to the aim of the WHO Code (i.e., to contribute to theprovision of safe and adequate nutrition for infants, by the protection and promotion ofbreast-feeding, and by ensuring the proper use of breast-milk substitutes, when these
are necessary, on the basis of adequate information and through appropriate marketingand distribution). That is, the Group supports and promotes exclusive breastfeeding forthe first six months of life and thereafter, the introduction of adequate complementary
food (baby food) while breastfeeding continues up to two years of age or beyond.
The Asahi Group recognizes that breast milk is the best nutrient source for infants. On
the other hand, the Group also recognizes that there are cases where breastfeeding is
not possible or cannot be continued for various reasons. In such cases, the Group
recognizes the significance of the role that BMS play in supplying safe and adequate
nutrition to infants.

The Asahi Group’s Marketing Policy for BMS
The Asahi Group’s BMS marketing policy is prepared on the basis of the WHO Code.
The following describes the Asahi Group’s BMS marketing policy related to Articles 1 to
11 of the WHO Code.
Article 1: Aim
The aim of this BMS marketing policy is to contribute to the health of infants and young
children by recognizing the importance of the aim and principle of the WHO Code, byprotecting, promoting, and supporting breastfeeding, and by ensuring the proper use of
BMS, when these are necessary, on the basis of adequate information and throughappropriate marketing and distribution.
Article 2: Scope of application of the Asahi Group’s BMS Marketing Policy
2-1. Scope of application to the organization
The Asahi Group’s BMS marketing policy applies to all the Employees (relevant
Employees) of the Group who engage in the marketing and/or sales of the“Covered Products”. Relevant employees and third parties authorized to act
under the instruction of the Asahi Group are required to comply with this BMS
marketing policy.
On the other hand, as for third parties not authorized to act under the
instruction of the Asahi Group, there is a limitation to the Company’s ability toaffect the advertisement and sales promotion of the “Covered Products” carriedout by such third party. If permitted by law of the relevant country, the Company
will work to have such third parties understand our BMS marketing policy,
especially with a focus on advertisement and sales promotion activities.
2-2. Regions to which this policy applies
In lower-risk countries including Japan, we will comply with all of such country’s
domestic regulations relating to BMS marketing and sales promotion to
implement the WHO Code.
As for higher-risk countries, if the country’s law to implement the WHO Codeis stricter than this BMS policy, we will adhere to that country’s law in addition
to the BMS policy. The term “higher-risk countries” is defined as countries
satisfying either of the following criteria according to the BMS Marketing Criteria
of FTSE4Good and are described in Annex 1. Furthermore, countries other thanthe higher-risk countries are classified as lower-risk countries:■ The mortality rate of children less than 5 years of age is 10 or more per 1,000
children, or■ The acute malnutrition (moderate and severe debilitation) of children less than
5 years of age is 2% or more.

2-3. Scope of application to products (hereinafter, “Covered Products”)
In the higher-risk countries, this BMS marketing policy will apply to the following:(i) Infant Formulas (prescribed to satisfy the ordinary nutritional requirement of
an infant of 0 to 12 months old) and information on the use thereof;(ii) Follow-up Formulas (limited to those intended for infants under the age of 12months) and information on the use thereof;(iii) Complementary Foods and beverages for infants under the age of 12months and information on the use thereof; and(iv)Delivery products（i.e. teats and bottles）, and information on the use
thereof.
Note that, products intended for use to infants and young children sufferingfrom a particular disease as instructed by a Healthcare Professional (hereinafter,“HCP”) (special dietary foods, foods for sick people) are not included in the“Covered Products”. These products include, for example, soymilk using
soybean milk powder for infants suffering from an allergic disease, and oral
rehydration solutions to supply water and electrolyte in the case of dehydration
due to viral gastroenteritis.
Article 3: Definitions
The definitions of the terms are described in Annex II.
Article 4: Information and education
4-1. The Asahi Group supports the government of each country to ensure that
objective and consistent information on infant nutrition is provided for use by thefamilies raising infants and those involved in the field of infant nutrition.
4-2. All informational and educational materials dealing with the feeding of infants,
which are intended to reach pregnant women and mothers of infants, describe

the contents concerning the items (a) to (e) of Article 4.2 of the WHO Code asshown below:(a) the benefits and superiority of breast-feeding;(b) maternal nutrition, and the preparation for and maintenance of breastfeeding;(c) the negative effect on breastfeeding of introducing partial bottle-feeding;(d) the difficulty of reversing the decision not to breastfeed; and(e) where needed, the proper use of infant formula, whether manufactured
industrially or home-prepared.
These materials describe information on the health hazards of unnecessaryor improper use of the “Covered Products”, and do not use any pictures or text
which may idealize the use of the “Covered Products”. The Asahi Groupconsiders that idealization refers to the wording and communication suggestingthat Infant Formulas are superior or equal to breast milk.
4-3. Informational or educational materials and/or equipment concerning the healthof mothers, infants, and young children which are provided to pregnant womenand mothers of infants and young children for the purpose of use of suchmaterials and/or equipment at Healthcare Entities (hereinafter, “HCE”) cannot
bear the product name (including the name of the series and the name of brand)
and/or logo of the “Covered Product”, but may bear the company’s name or logo.
Such materials and/or medical treatment-related articles are provided onlyat the request and with the written approval of the appropriate government
authority, HCE, or HCP, or within guidelines given by the government for thispurpose. These materials and educational equipments are distributed only
through the HCE or HCP.
Article 5: General consumers and mothers
5-1. The Asahi Group does not carry out any advertisement or any form of sales
promotion for the “Covered Products” to general consumers.
5-2. The Asahi Group provides no samples of the “Covered Products” directly or
indirectly to pregnant women, mothers, or family members of infants.
5-3. The Asahi Group does not use point-of-sale advertising, the giving away ofsamples, or any other sales promotion means to sell the “Covered Products”
directly to consumers at the retail level. Such sales promotion means include,
but are not limited to, the following:- Special displays;- Discount coupons;- Sales with premiums;- Special sales; and- Tie-in sales.
This provision does not, however, restrict the establishment of pricing policies
and practices intended to provide products at low prices on a long-term basis.
5-4. The Asahi Group does not distribute to pregnant women or mothers of infants
any gifts of articles or utensils which may promote the use of the “Covered
Products” or bottle-feeding.
5-5. No employee of the Asahi Group contacts pregnant women or mothers of infants
directly or indirectly for the purpose of selling the “Covered Products”. This does
not, however, restrict employees of the Asahi Group from directly responding to
the questions from consumers concerning the “Covered Products” through thetelephone helpline, website, and/or social media.
Article 6: Health care system
6-1. Article 6.1 of the WHO Code is addressed to government authorities in chargeof health care.
6-2. The Asahi Group does not use HCE for the purpose of promoting sales of the“Covered Products”. This does not, however, restrict it from directly providing
HCP with scientific or technical product information, as set out in Article 7.2 ofthis BMS marketing policy.
6-3. The Asahi Group does not display the “Covered Products”, or placards orposters at HCE. Furthermore, the Asahi Group prohibits distributing any
materials for the “Covered Products” in the HCE, except in the cases set forthin Articles 4.2 and 4.3 of this BMS marketing policy.

6-4. The Asahi Group does not, directly or indirectly, provide to HCE or pay for
professional service representatives, childcare counselors, or similar personnel.
6-5. No employee of the Asahi Group is involved in directly providing to mothers or
their family members an explanation and demonstration of feeding with Infant
Formula. Those who engage in such acts are limited to a Health Worker or othercommunity workers (i.e., community consultants or volunteers). Employees of
the Company may provide relevant educational and guidance materials to
support Health Workers in fulfilling their responsibilities.
6-6. The Asahi Group may donate or supply the “Covered Products” free of charge
or at low price only when in response to a particular written request from thegovernment, HCE, or a proper aid agency. Such Supplies will be distributed only
to the infants for whom the Health Worker determines that feeding with the“Covered Products” is needed. The Supplies are not provided to Health Workers
or HCE as a sales inducement.
6-7. The Asahi Group is aware of the following responsibility as a donor, which isbased on Article 6.7 of the WHO Code.

6-8. The materials and/or medical treatment-related equipment, in addition to thosedefined in Article 4.3, donated to HCE may bear the Company’s name and/or
logo, but may not state the brand name or logo of the “Covered Products”. The
materials and/or practice-related articles are provided only to HCE, and suchprovision is based on HCE’s written request and is carried out in accordancewith HCE’s and the Asahi Group’s transparent, established, and bona fideprocurement, billing, and, where applicable, payment procedures.
Article 7: Health Worker
7-1. The Asahi Group endeavors to ensure that Health Workers become familiar with
their responsibilities under the WHO Code.
7-2. The Marketing Personnel of the Asahi Group provide, to HCP, only the objective
and scientific information based on the facts related to the “Covered Products”.
Such information does not imply or create a belief that bottle-feeding isequivalent or superior to breast-feeding. Furthermore, such information clearly
indicates that this is for HCP’s exclusive use and states the information
described in Article 4, paragraph 2of this BMS marketing policy.
7-3. No financial or material inducements to promote sales of the “Covered Products”
are offered by the Asahi Group to Health Workers or members of their families.
(i) If permitted in accordance with the local laws and regulations and (ii)permitted due to consistency with the Company’s internal policy and procedures,
the

Asahi

Group

may

give

to

HCP

a

small,

inexpensive,

cultural/social/ceremonious gift on an occasion of important national, cultural,or religious event. Such gift items do not evoke recommendation of the“Covered Products”, are irrelevant to the work of Health Workers, and do notbear the brand name or logo of the “Covered Products”.
7-4. The Asahi Group does not provide to HCP any samples of the “Covered
Products” and/or equipment or utensils relating to preparation of the “Covered
Products” except when necessary for the purpose of professional evaluation or
research at the institutional level. In the case of the Product for Professional
Evaluation (hereinafter, “PPE”) of the “Covered Products” and/or equipment or
utensils relating to preparation of the PPE, it is possible to provide them to HCP
in the following cases:- When introducing a new “Covered Products” or package/label of the “Covered
Products”;- When introducing a new ingredient/recipe of an existing product;- When presenting the “Covered Products” to a new or recently qualified HCP;and
- When obtaining data on the professional evaluation and efficacy of the“Covered Products”.
The label or Container of the PPE states at least the text: “For professional
evaluation—reselling prohibited,” or, if there is a text clearly required by local
law or regulation, states as required. The distribution of the PPE of the “Covered
Products” is made only when requested by a document approved by HCP. At
that time, the document shall clearly state at least the following:- The requested PPE is used only for the purpose of professional evaluation;- PPE is in need;- HCP recognizes his/her own obligations defined under the relevant laws andregulations in the country where he/she resides, and agrees to respect suchobligations;- PPE is not provided as an incentive for purchase, reselling, or recommendationof the “Covered Products” of the Asahi Group; and- PPE will not be resold nor taken out of the office for personal use by HCP or
his/her staff.
7-5. To promote continuous professional expertise development and training, theAsahi Group may make any contribution to HCP himself/herself or on his/herbehalf for fellowships, study tours, research grants, attendance at professional
conferences, or the like in accordance with relevant laws and regulations.
Information on such contribution will be disclosed to the institution to which the
HCP is affiliated.
The Asahi Group may, if permitted by local laws and regulations, conclude acontract on piecework with HCP as a speaker or consultant to provide service
to the Asahi Group. The HCP to the contract on piecework is compensated withthe amount not exceeding the proper market price for such service as
determined in accordance with the internal company rules and procedures of
the Company. Transportation costs, accommodation costs, and cost of meals
incurred as a part of the service, which are reasonable and comply with internal
company rules and procedures of the Company, may be reimbursed. HCP’s
personal costs, such as the expenses incurred from HCP’s entertainment or
his/her accompanied spouse or other invited guest/s, or the expenses resulting
from staying longer than needed, may not be reimbursed.
Article 8: Persons employed by Manufacturer and Distributor
8-1. None of the target volume of sales, target amount of sales, or quotas for sales
especially set for the “Covered Products” is included in the calculation of
bonuses or incentives to Employees of the Asahi Group. This does not preventthe payment of bonuses based on the overall sales of the products marketed by
the Asahi Group.
8-2. The Asahi Group’s Marketing Personnel in charge of the “Covered Products”
may not perform educational functions regarding the “Covered Products” at the
HCE in relation to pregnant women and mothers of infants. This does not,

however, prevent the Marketing Personnel from performing other work (otherthan the educational functions regarding the “Covered Products”) at the HCE at
the request and with the written approval of the proper authority. Furthermore,in such cases, the Marketing Personnel acts while taking into account Article 4,paragraph3, Article 5, paragraph 5, and Article 7, paragraph 2 of this BMS
marketing policy.
Article 9: Labelling
9-1. The Labels of the “Covered Products” are designed to provide all the necessary
information about the safety and appropriate use of the Products, and must notprevent breastfeeding in accordance with the local laws and regulations(including those contained in Codex Alimentarius if applicable).
9-2. Unless otherwise provided for by law, the Labels of Infant Formulas must be a
printed Label which cannot readily become separated from the package or
product. The Label must be clear, conspicuous, and easily readable andunderstandable, in an appropriate language, which must include all the following
points:(a) the words “Important Notice” or their equivalent;(b) a statement of the superiority of breast-feeding;(c) a statement that the product should be used only on the advice of a healthworker as to the need for its use and the proper method of use; and(d) instructions for appropriate preparation, and a warning against the healthhazards of inappropriate preparation.
The requirement of “in an appropriate language” shall conform to thedetermination of a relevant authority.
Neither the Container nor the Label of Infant Formula should have pictures
or illustrations of infants, nor should they have other pictures or text which may
idealize the use of Infant Formula. They may, however, have graphics for easy
identification of the product and for illustrating methods of preparation. The
terms “humanized,” “maternalized,” or similar terms should not be used.
9-3. Food products marketed for infant feeding, which do not meet all therequirements of an Infant Formula, but which can be modified to do so, should
carry on the Label a warning that the unmodified product should not be the sole

source of nourishment of an infant.
9-4. Unless otherwise provided for by law, the Labels of the “Covered Products” state
the following points in addition to the specific age for use:(a) the ingredients used;(b) the composition of nutritional ingredients/analysis of the product;(c) the storage conditions required; and(d) the batch number and the date before which the product is to be consumed,
taking into account the climatic and storage conditions of the country
concerned.
Article 10: Quality standard
10-1. To ensure the protection and health of infants, the Asahi Group manufactures
all the “Covered Products” under strict hygiene control and quality control
procedures.
10-2. The “Covered Products” sold or distributed must meet the applicable quality
standard and hygiene standard, or local laws and regulations (including thestandards recommended by the Codex Alimentarius Commission if applicable).
If the quality standard of the Asahi Group is stricter than that of the local
regulations, the Asahi Group’s quality standard takes precedence.
Article 11: Implementation and monitoring
11-1. The government of each country is responsible for the implementation andinterpretation of the WHO Code. In all the countries where the Asahi Groupdevelops its business, the Company cooperates with the governments andother stakeholders in the establishment of local laws and regulations related tothe implementation of the WHO Code and in the implementation of othermeasures.
11-2. The Asahi Group cooperates with the governments and other stakeholders in
the monitoring of the status of application of the WHO Code.
11-3. Independent of any other measures taken by the governments to implement the
WHO Code, the Asahi Group promises to monitor its own marketing practices
according to this BMS marketing policy.

We take measures to check and confirm that our acts conform with the BMS
marketing policy. To support the monitoring of our marketing practices, theCompany’s approach to monitor the compliance is outlined in the section of “TheAsahi Group’s Implementation Procedures for the Marketing of BMS” of thisBMS marketing policy.
11-4. The Asahi Group encourages its Employees and other stakeholders to sharematters of concern about the BMS marketing practices of the Company so thatappropriate corrective action can be taken as necessary.
11-5. The Asahi Group apprises the Marketing Personnel and third parties on theirbehalf involved in the marketing of the “Covered Products” of their
responsibilities to comply with all the relevant local laws and regulations that are
applicable to the BMS marketing policy as well as the marketing, distribution,and sales of the “Covered Products”.
11-6. Article 11.6 of the WHO Code provides the content that the government of eachcountry should deal with.
11-7. Article 11.7 of the WHO Code provides the content that the WHO DirectorGeneral should deal with.

The Asahi Group’s Implementation Procedures for the Marketing of
BMS
1. Appropriate policy and procedures
The Asahi Group promises to establish the documented policy and procedures that may
help the Employees and a third party authorized to act under the instruction of the Asahi
Group in understanding the WHO Code, local laws and regulations concerning themarketing of BMS, and the Company’s BMS marketing policy.
The Asahi Group guarantees to periodically review and renew the supporting policy
and procedures as well as the internal guidelines on the basis of local laws andregulations and/or any changes to the BMS marketing policy of the Company.
2. Training and communication
The senior management officers and Employees of the Asahi Group in all the countries
who are involved in the sales/marketing of the “Covered Products” are given training andare thereby apprised of the importance of protecting and supporting breastfeeding
including the WHO Code as well as this BMS marketing policy and procedures. The
records of the training are documented in writing and confirmed and verified internally.
3. Responsibility
To have a clear-cut role and responsibility is extremely important in supporting theeffective governance and compliance processes. In order to ensure appropriatemonitoring, the Asahi Group assigns process and responsibility to particular
individuals/groups as follows.
In the Asahi Group, the Group Chief Sustainability Officer (Group CSO) of Asahi
Group Holdings, Ltd. bears the ultimate responsibility for the BMS marketing policy. All
reports on the compliance with the BMS marketing policy are submitted to the GroupCSO to be subject to ultimate review and approval. The responsibility for management,
implementation, communication, and monitoring relating to the compliance with the BMS
marketing policy is delegated to the BMS Conference established by the Group CSO.
The members of the BMS Conference are composed of director/s of BMS-related
business, relevant senior management officer/s, head of each country’s responsible
business division, functional expert/s, compliance expert/s, and the like, and serve forapproval of BMS-related all the policies and annual reports and approval of correctiveplans for monitoring and indicated matters. Furthermore, the members receive periodic
reports on the status of progress and the implementation of corrective measures in the

BMS field from the head of the responsible division of each related business.
A team of experts having appropriate qualifications monitors the compliance with the
BMS marketing policy that is being implemented in different regions and periodicallyreports the results to the BMS Conference. All the policy formulations within the scopeof application of this BMS marketing policy are carried out by the corporate level of the
Asahi Group to secure the consistency of the approach and the separation from therespective BMS business sections. However, it is recognized that each country’s uniquelaw, guidelines, and/or local practices must be respected and adhered to. Consequently,
the head of the responsible division of each BMS-related business is responsible for local
implementation of the BMS marketing policy and secures the complete compliance inthe relevant region.
4. Monitoring and reporting
Continuous monitoring program is in place to ensure that the policy and procedures aswell as guidelines are applied appropriately and effectively.
<Monitoring>
The Asahi Group, as shown below, checks and confirms that on-site marketing practices
comply with the BMS marketing policy, and conducts numerous monitoring activities
planned for specifying inadequacies and points of improvement in the management.
a. Internal monitoring and audit
To check and confirm that the business section in each country (both lower-risk countries
and higher-risk countries) is operated in accordance with this BMS marketing policy andprocedures as well as the laws and regulations in the local place where the WHO Codeis implemented, the monitoring of the status of compliance with this policy is carried out
by the front-line BMS-related business section. Internal audits are conducted by anindependent internal audit section. All monitoring and audits to check and confirm
compliance with the BMS marketing policy are carried out in a continuous manner.
b. Whistle-blower scheme
A system called “Speak Up” has been set up to encourage early detection of risks
associated with corporate activities of the Asahi Group and to prevent risks fromdeveloping into serious problems. Where the matter involves a breach or potential
breach of the relevant laws and regulations or internal company rules, and where thematter cannot be resolved satisfactorily by management, whistle-blowers areencouraged to approach contacts either inside or outside the company by utilizing SpeakUp.
Anonymity is assured for all whistle-blower reports from inside and outside of thecompany in a way that protects them from any possible negative consequences.
c. External audit
The Asahi Group request an internationally recognized independent third-party
organization that has proper qualifications to check, confirm, and evaluate theeffectiveness of the Company’s policy, compliance management, and audit system in a
specific country at least once every two years.
d. Claim for compliance violation
The Asahi Group is provided with a clear-cut process and documented procedures forregistering, collating, investigating, tracking, and reporting any claim for the violation ofcompliance with the BMS marketing policy. Such claims from inside and outside of theCompany will be promptly investigated and (if necessary) improvement will be made,with a reasonable and swift response as our goal.
A claim for non-compliance with the BMS marketing policy may be received throughvarious communication means such as telephone, email, website, and letters, but themeans are not limited thereto. The content of such claim and the investigation/reporting
results are internally registered in an integrated fashion. The investigation of a claim forsuspected violation of the BMS marketing policy is carried out by the business
responsibility section of each country upon delegation by the BMS Conference, and if
the suspicion is proved, appropriate corrective measures shall be taken.
e. Principle of monitoring and investigation
The Asahi Group does not punish management personnel for the loss of business arisingfrom in connection with compliance with the BMS marketing policy. Furthermore, theAsahi Group guarantees that there is no retaliation to the Employee who has expressed
concerns in good faith about the known or suspected violation of the BMS marketing
policy and that such Employee will receive no disadvantageous decisions on his/her
employment because he/she has adhered to the BMS marketing policy.
<Reporting>Internal reporting ensures accountability, increases knowledge, and enhances
awareness in the business. This is useful not only for improving the benchmark of andcompliance with the BMS marketing policy of the Company, but also for attaining
consistency in the approach to and application of the policy. The internal reporting on adaily basis as to BMS-related topics is carried out at the BMS Conference and includes,
but not limited to, the following:a. Actual case of proved compliance violation;b. Summary of internal demonstration for compliance;c. Progress reporting and results of the internal monitoring/audit conducted;
d. Progress report and results by the external audit conducted; ande. Recommendation to corrective measures as a result of a), b), and c) or d) above.
Once a year, an annual report on compliance with the BMS marketing policy, which
has been approved at the BMS Conference, shall be submitted to the Board of Directorsof Asahi Group Holdings. Such report addresses the following, but the topics are notlimited thereto:a. Actual case of proved compliance violation;b. Summary of internal demonstration for compliance;c. Summary of the internal and external monitoring and/or audit conducted and of theresults; andd. Recommendation to corrective measures and the related schedule as a result of a),b), and c) above.
Reporting to outside parties provides an opportunity of constructive involvement withmajor stakeholders while respecting the pledge of the Asahi Group for transparency andinvolvement. The Asahi Group promises to disclose at least the following information to
the general public in relation to the implementation of the WHO Code by the governmentof each country and compliance with the BMS marketing practices in all the countries
where the Asahi Group develops its business:a. Policy on purpose and practice of the Company’s lobbying in relation to theimplementation of the WHO Code by government (see 6. Support activities);b. Public announcement of the industry groups and industry policy groups to which the
Asahi Group is affiliated while endeavoring for their operations under high standards;c. An annual report on an illustrative case of demonstrated compliance violation and thecorrective measures that have been implemented; andd. An external audit report on compliance with the BMS marketing policy and thecorrective measures that have been implemented.

5. Corrective measures
The identification and implementation of a corrective measure plan are importantelements for the Company’s governance approach, which ensures that a proven violationof the BMS marketing policy or against the local law or regulation that regulates themarketing of the “Covered Products” is properly reported and corrected as a result of thefollowing monitoring activities:- Internal monitoring or audit;- External audit;- Individual whistle-blower scheme (Speak Up, Customer Relations Office); and- Other reporting on the proved compliance violation.
6. Support activities
In support of the aim of the WHO Code, the Asahi Group supports the sound andhealthy growth and development of infants and young children by protecting,promoting, and supporting breastfeeding and safe, appropriate, and adequate
nutritional supplement to infants and young children, and makes efforts to contribute to
the realization of a sustainable society. To advance this, the Asahi Group recognizes
that it is important to establish partnerships with a wide range of stakeholders such as
those who engage in the business environment, including governments, regulatory
authorities, legislators, civil societies, and other companies in the same industry and tocooperate with such persons. When conducting lobbying related to the implementationof the WHO Code and subsequent relevant WHA resolutions, the Company focuses on
the following points:- To share viewpoints, we make efforts to establish periodic and consistent relationships
with external stakeholders;- The involvement and support activities that are direct or via industry groups shall betransparent and based on facts;- We make efforts for the industry groups and industry policy groups, to which we areaffiliated, to be operated under the same high standards, and disclose that we are amember of such organizations. If we are unable to agree with decisions of an industry
group or the position of another company, we will have such disagreements be known
to all the persons concerned. We make efforts to modify such decisions or position anddo not become involved in positions with which we disagree;- We maintain transparency about our own position and communicate the position to thestakeholders concerned;- Our lobbying and advocacy activities will be carried out in accordance with local

regulations if any; and- We cooperate with governments and other stakeholders in the establishment of local
laws and regulations concerning the implementation of the WHO Code and in themonitoring of the status of implementation and application of other measures.
The end of the document<History>
Issued in July 2017.
Amended in August 2020.
Amended in August 2024.

Annex I: List of higher-risk countries
Afghanistan

Comoros

Indonesia

Namibia

Solomon Islands

Cook Islands

Iran

Nauru

Somalia

Algeria

Costa Rica

(Islamic Republic)

Nepal

South Africa

Angola

Korea

Iraq

Nicaragua(Republic of) South

Cote d’Ivoire

Niger

Sudan

Jamaica

Nigeria

Sri Lanka

Jordan

Niue

Sudan

Kazakhstan

Oman

Suriname

Pakistan

Eswatini (former

Palau

Swaziland)

Albania

Antigua andBarbudaArgentina
Armenia

Republic of Congo
Djibouti
Dominica

Azerbaijan

Dominican Republic Kenya

BahamaEast Timor

Kiribati

Bahrain

Ecuador

KuwaitBangladesh

Egypt

Barbados
Belarus
BelizeBenin
BhutanEl Salvador
Equatorial Guinea

Herzegovina

Lao People’s
Democratic Republic
Lebanon

Eritrea

Lesotho

Ethiopia

Liberia

Federated States of Libya

Bolivia
Bosnia andKyrgyzstan

Micronesia

Madagascar

Fiji

Malawi

Botswana

Republic of

BrazilMacedonia

Bulgaria

Gabon

Burkina Faso

Malaysia

Palestinian Territory Syrian Arab Republic
PanamaTajikistan

Papua New Guinea Thailand
Paraguay

Togo

Peoples Republic of Tonga
Congo

Trinidad and Tobago

Peru

Tunisia

Philippines

Türkiye

Qatar

Turkmenistan

Republic of Moldova Tuvalu
Romania

UgandaMali

RussiaUkraineMarshall Islands

RwandaUnited Arab Emiratis

Gambier

Mauritania

Saint Christopher

Tanzania

BurundiGeorgia

Mauritius

and Nevis

Uruguay

Cambodia

Ghana

MexicoSaint Lucia

Uzbekistan

Mongolia

Saint Vincent andVanuatuMontenegro

the Grenadines(Republic of)

MoroccoSamoa

Venezuela

Mozambique

Sao Tome andViet Nam

MyanmaCameroon
Cabo VerdeCentral African
Republic
Chad

GrenadaGuatemalaGuineaGuinea-Bissau

Maldives

Principe

Yemen

China

GuyanaSaudi Arabia

ZambiaColombia

Haiti

SenegalZimbabwe

HondurasServiaIndia

Seychelles
Sierra Leone* Defined in the FTSE4Good adoption criteria for the marketing of Breast-milk Substitute in July 2017

Annex II: Definitions of terms■ Breast-milk Substitute: BMS
Any food marketed or displayed as partially or wholly substituting breast milk, apart fromwhether such food suits the purpose.
■ Infant Formula
Artificial milk prescribed to satisfy the ordinary nutritional requirement of an infant of 0
to 12 months old.
■ Follow-up Formula
Artificial milk commercially available for the purpose of receiving nutrition necessary for
an infant, which is used concurrently with Complementary Foods.
■ Complementary Food
Any food that supplements breast milk or Infant Formulas when (breast milk or artificial
milk alone become) inadequate to satisfy the nutritional requirement necessary for an
infant. Such food is generally called “baby food” or “food supplementing the nutrition ofbreast milk.”■ “Covered Products”
Pursuant to the definition in “Scope of application to products” of Article 2 of this BMS
policy.
■ Excluded ProductPursuant to the definition in “Scope of application to products” of Article 2 of this BMS
policy.
■ Product for Professional Evaluation: PPE
A small amount of “Covered Products” that is provided free of charge to HCP for the
purpose of an evaluation of the Product conducted by expert.
■ Sample
A small amount of or a single “Covered Products” that is provided free of charge. PPE
is not included.
■ Supplies
A certain amount of “Covered Products” provided for use, free of charge or at a low
price for a certain period in time for volunteer social service purposes. This includes
cases of providing to families in need of the “Covered Products”.
■ Delivery ProductProduct used when taking the “Covered Products” (feeding teats and bottles)■ Container
Any form to pack and retail the “Covered Products”. Wrapping paper is included.

■ LabelThis refers to any tag, trademark name, mark, picture or drawing, and instructions thatare attached to the Container of the “Covered Products”, including cases where suchinformation is displayed directly on the Container by hand-writing, printing, stencil printing,stamping, embossing, or indenting, or by other means and cases where such information
is indirectly attached as an attachment or the like.
■ Employee
This refers to those who are employed by a permanent or temporary contract with the
Asahi Group, or employed at will by the Asahi Group, or employed under the joint venture
whose management right is held by the Asahi Group. For the purpose of this BMS
marketing policy, Employees do not include the individuals who provide service as aconsultant or independent contractor, and individuals who are employed by anotherbusiness entity such as employees of an agency.
■ A third party authorized to act under the instruction of the Company
This refers to a Distributor formally approved by the Company, which has a direct
service relationship and/or contractual relationship with the Asahi Group (AuthorizedDistributor).
■ Distributor
This refers to a corporation, company, or any other business entity public or private thatengages in the marketing business at the wholesale or retail level handling the “Covered
Products”.
■ Manufacturer
This refers to a corporation or any other business entity public or private that engages
in the business or duties to manufacture the “Covered Products” (whether directly,
through a managed agency, or in contract with such agency).
■ Healthcare Entity: HCE
This is defined as governmental, non-governmental, or private institutions ororganizations that engage in providing healthcare to pregnant women, mothers, andinfants and young children. This includes facilities where a Health Worker personallyprovides healthcare, but does not include personal residences, pharmacies, and anyother existing stores.
■ Health Worker
This is defined as a person who works while being involved in the health system,
professional or non-professional, and includes unpaid volunteers.
■ Healthcare Professional: HCP
This refers to a person who is in a position of providing healthcare service orrecommending, managing, and affecting the purchase or use of the relevant products of
the Asahi Group, including physician, nurse, nutritionist, medical assistant, midwife,
resident, and pharmacist, but not limited to these job types.
■ Marketing
This refers to sales promotion, distribution, sales, advertisement, public relation
activities, and information service for the “Covered Products”.
■ Marketing Personnel
All the Employees who work in relation to the marketing of the “Covered Products”.
■ WHO CodeInternational norms concerning the marketing of Breast-milk Substitutes as formulated
and then endorsed by WHO in 1981.
■ WHA
This refers to the World Health Assembly.

Annex III: List of Relevant Affiliated Organizations
Japan Dairy Industry Association
Japan Baby Food Committee