Asahi Beverages Whistleblowing Procedure –For disclosures by External Persons
Applies toIn Australia this procedure applies to individuals including:•former officers, employees and associates;•relatives of our current and former officers, employees and associates;•our current and former contractors, consultants, service providers, suppliers, and theiremployees; or•relatives of current and former contractors, consultants, service providers, suppliers and theiremployees, including a spouse (including de facto), or dependant.

In New Zealand, this procedure applies to the following persons who are eligible to make protecteddisclosures under the Protected Disclosures (Protection of Whistleblowers) Act 2022 (NZ) (PD Act) but
are not currently employed, engaged, or involved in the Asahi Beverages business:•former volunteers, employees, or secondees;•

persons who were formerly engaged or contracted under a contract of services to do work for
Asahi Beverages; or•

persons who were formerly concerned in the management of Asahi Beverages.

Procedure - Australia
In Australia, if you have a concern about Improper Conduct (as defined below) occurring in relation toour business, you may use our Speak Up System, operated by Navex and accessible via
asahigroup.ethicspoint.com or by telephone on 1800 518 251 (Australia). The Speak Up System isconfidential and is independently operated by Navex 24 hours a day, 7 days a week.
You can raise your concern anonymously. A disclosure made to our whistleblowing hotline will be treatedwith discretion. The identity of a discloser (or information likely to lead to a discloser being identified asa discloser) will be kept confidential, except to the limited extent advised otherwise. You may be required
to sign a confidentiality agreement in relation to information we provide to you about the investigation.
Your concern must be based on reasonable grounds and relate to Improper Conduct outlined below:
Improper Conduct

Example/s

Misconduct in relation to Asahi Beverages.

Deliberately or negligently breaching laws in theconduct of our business or the person’s duties.

Misconduct includes fraud, negligence, default,
breach of trust, or breach of duty in relation toAsahi Beverages.

Deliberately overcharging customers or charging
customers for services they did not receive.

An improper state of affairs or circumstances, inrelation to the Asahi Beverages.

Unethical conduct, such as systemic or serious
breaches of our Code of Conduct, Bribery andAnti-Corruption Policy.
Conduct which may cause financial or nonfinancial loss to Asahi Beverages or be otherwise
detrimental to the interests of Asahi Beverages,
such as financial mismanagement.

Information that indicates that the Asahi
Beverages or any of our officers or employees
have engaged in conduct that constitutes abreach of the Corporations Act or other laws
administered by ASIC and APRA, such as:
Corporations Act; ASIC Act 2001; Banking Act
1959; Financial Sector (Collection of Data) Act
2001; Financial Accountability Regime Act 2023;
Insurance Act 1973; Life Insurance Act 1995;
National Consumer Credit Protection Act 2009;
Superannuation Industry (Supervision) Act 1993;
or any instrument made under those Acts.

Insider trading.
Trading while insolvent.
Breach of continuous disclosure rules.
Engaging in detrimental conduct towards a
person who is, or is thought to be, a discloser.
Revealing the identity (or information likely to leadto identification) of a discloser (except inpermitted circumstances).
Falsification of accounts.
Failure of a director, or another officer, to act withthe care and diligence a reasonable person would
exercise, or to act in good faith in the bestinterests of the corporation, or to give notice ofany material personal interest relating to theaffairs of Asahi Beverages.

Information that indicates that Asahi Beverages
or any of our officers or employees have engaged
inconductthatbreaches
anyotherCommonwealth laws, that is punishable by 12months or more imprisonment.

Bribing a government official.

Information that indicates that Asahi Beverages
or any of our officers or employees have engaged
in conduct that represents a danger to the public
or the financial system.

Deliberately or negligently misleading the public
about the safety of a product.

Information that indicates misconduct or animproper state of affairs or circumstances, inrelation to the tax affairs of Asahi Beverages orassociated entity.

Information about a tax evasion scheme within
the business.

Concerns about the actions of a third party.

A supplier asking
arrangement.

Conduct contrary to, or a serious breach of,codes and practices (including work practices) of
Asahi.
Any attempt to conceal or delay disclosure of anyof the above conduct.
Procedure – New Zealand

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Breach of work, health and safety laws.

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In New Zealand, if you have a concern about Improper Conduct (as defined below) occurring in relation
to our business, you may use our Speak Up System, operated by Navex and accessible via
asahigroup.ethicspoint.com or by telephone on 0800 459 601 (New Zealand). The Speak Up System isconfidential and is independently operated by Navex 24 hours a day, 7 days a week.
In New Zealand, Improper Conduct means serious wrongdoing as defined in the PD Act, which
includes any act, omission, or course of conduct in or by Asahi Beverages that is one or more of thefollowing:1.

an offence;2.

a serious risk to public health, public safety, the health or safety of any individual or theenvironment;

3.

a serious risk to the maintenance of law, including the prevention, investigation and detection ofoffences or the right to a fair trial;

4.

an unlawful, corrupt or irregular use of public funds or public resources;

5.

oppressive, unlawfully discriminatory, grossly negligent, or that constitutes grossmismanagement, and is done (or is an omission) by an employee (if the organisation is a public
sector organisation); or a person performing (or purporting to perform) a function or duty orexercising (or purporting to exercise) a power on behalf of a public sector organisation or theGovernment.

A report of Improper Conduct will be a protected disclosure under the PD Act in New Zealand provided
that you believe on reasonable grounds that there is, or has been, serious wrongdoing within Asahi
Beverages, you disclose that serious wrongdoing in accordance with the PD Act, and do not disclose it
in bad faith.

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