WORKPLACEDECEMBER 2021

CODE

BREWDOGMISSIONOUR MISSIONIS TO MAKE
OTHER PEOPLE
AS PASSIONATEABOUT GREAT
BEER AS WE ARE.
0203

CHARTER

FOR BETTERBEER.
FOR A BETTER
PLANET.

04

POWERED BYPEOPLE.
FOR US ALL.

05

BREWDOG

DOGMAS
CODE OF CONDUCTDOGMAS

BE WHERE
THE ACTION IS

WE ARE A
MERITOCRACY

COUNT TIME IN
DOG YEARSOWNYOURNUMBERSCHALLENGE
EVERYTHING

06

07

BREWDOG

WORKPLACEWORKPLACE CODE

CODE

SINCE STARTING OUR BUSINESS AS TWO MEN
AND A DOG, OUR MISSION AS A BUSINESSHAS BEEN TO MAKE OTHER PEOPLE AS
PASSIONATE ABOUT GREAT CRAFT BEER AS
WE ARE. WE HAVE AN UNRELENTING AMBITIONTO INTRODUCE MORE PEOPLE TO GREAT BEER,
AND TO ENGINEER A WHOLE NEW TYPE OF
BUSINESS MODEL.

We value our people and we want to create an environment
in which our people feel supported, but are also able to maketheir own decisions. This document is intended to provide
guidance to our crew on the standards we expect acrossthe business.

08

It isn’t always obvious what the right thing to do is in a situation,
and we’re keen for you to have the tools to enable you to make thebest decisions in various areas, ranging from human rights anddiversity to data privacy and information security. This document
helps our crew be sure that what they’re doing is in line with our
Mission, Charter and Dogmas

K TO YOU R
IF YOU ’RE EVE R IN DO UBT, TALPER SO N
LIN E MA NAG ER, OR ANOTHE R
INE SS ARE A,
RES PO NSI BLE FOR YOU R BUS
LIN E.
OR CO NTACT THE LISTEN ING

IF YO U’R E RE SP ON SIB LE
FO R LE AD ING ON E OFOU R CR EW S, IT’S YO UR
RE SP ON SIB ILI TY TO
MA KE SU RE YO UR CR EW
UN DE RSTA ND S OU R
BU SIN ES S PR ACTIC ES AN
D WO RK PL AC E CO DE
WH ICH WE ’VE SE T OU T
IN TH IS DO CU ME NT AN DINOU R SU PP OR TIN G PO LIC
IES, AN D HOW TO AP PLY
TH EM AC RO SS YO UR CR
EW ’S OP ER AT ION .

IF YOU FEEL SOMETHING ISN’T RIGHT,
IT PROBABLY ISN’T. PLEASE SPEAK UP
AND SHARE YOUR GENUINE CONCERNS,KNOWING THAT WE WANT TO HEAR THEM.

09

BREWDOGR
OUR
PEOPLEOUR PEOPLENOTHING IN THIS DOCUMENT IS INTENDED TO
LIMIT OR INTERFERE WITH YOUR RIGHTS AS
AN EMPLOYEE. IF SOMEONE’S BEHAVING IN A
WAY THAT’S NOT IN LINE WITH THIS DOCUMENTOR IN A WAY THAT’S HARMFUL TO OUR CREW,CUSTOMERS, OR BUSINESS, WE’D LIKE TO KNOWABOUT IT SO PLEASE SHARE YOUR CONCERNSBY REPORTING IT.

Most of the time, the best way to deal with any issues or concerns
can be dealt with by talking to your line manager, or anotherperson responsible for your area. Any genuine issues, or concerns
raised in good faith, will be taken seriously and will always be
investigated in a fair, confidential and balanced way. We all havea responsibility to fully co-operate with any investigations thatare required.
We value your help in identifying any misconduct. We prohibit
retaliation of any kind against anyone who shares a good faithconcern or helps with an investigation into a possible breachof this document. We define retaliation in our document assomething that may deter you from reporting any concerns to us.

IF YO UFEELUNCOM
FO RTATA L K IN
BLEGM A N AG TO YO U R L IN
ER OR
E
S O M EOE LS E A
NE
T WO RK , YO U
SHOULDT H E L IS C O N TACTT E N IN G
L IN E .

010

011

OUR PEOPLE

THEY RBEE
LOV E

OUR PEOPLESHARE SOMECOMMONBEHAVIOURS

THEY ASKTHEI RMAN AGERFOR REGU LARFEED BACK

THEY ARE SELF - S TA R

UT
KO ,
E
E
P
YS
SHI NDT H E N TO RA
M E N A L LY LYALER
INT TERNEX

TERS

T H E Y AC T
IN T H E R O
LETH E Y ASP
IR E
TO - N OT
THE ROLET H E Y ’R E IN

S
LOT
K
S
YA
ONS
TH E U ESTI
Q
OF

THEY
ENCO URAG E
EVER YONE AT
BREW DOG TO
BE THEM SELV ES
AT WOR K

012

TH
REL EY ARE
E
CU R NTLESS
IOUS
LY
A
ALL
ARE BOUTA
THE
BUS S OF
INES
S

THE

YA
OF RE SUPM E M OT H E R P O R T
IVE
C
BER
S A REW
LW A
YS

013

BREWDOG

THE LISTENING LINETHE
LISTENING
LINE
BREWDOG IS AN ORGANISATION WITH STRONGVALUES OF RESPONSIBILITY AND INTEGRITY. WE
ARE COMMITTED TO AN ENVIRONMENT WHERE
OPEN, HONEST COMMUNICATIONS ARE THE
EXPECTATION, NOT THE EXCEPTION. WE WANT YOU
TO FEEL COMFORTABLE IN APPROACHING YOUR
LINE MANAGER OR ANY MANAGER IN INSTANCESWHERE YOU BELIEVE OUR POLICIES OR CODE ARE
NOT BEING FOLLOWED.

THE INFORMATION YOU
PROVIDE WILL BE SENTTO US BY ETHICSPOINT ON
A TOTALLY CONFIDENTIAL
AND ANONYMOUS BASIS IF
YOU CHOOSE. YOU HAVE OUR
GUARANTEE THAT YOURCOMMENTS WILL BE HEARD.

IN SITUATIONS WHERE YOU PREFER TO PLACE AN
ANONYMOUS REPORT IN CONFIDENCE, YOU ARE
ENCOURAGED TO USE THIS HOTLINE, HOSTED BY A
THIRD-PARTY HOTLINE PROVIDER, ETHICSPOINT.
YOU ARE ENCOURAGED TO SUBMIT REPORTS
RELATING TO ANY BREACHES OF OUR POLICIES,AS WELL AS ASKING FOR GUIDANCE RELATEDTO POLICIES AND PROCEDURES AND PROVIDINGPOSITIVE SUGGESTIONS AND STORIES.

014

015

BREWDOG

THE LISTENING LINE

CTA BLE 24
THE LIS TEN ING LIN E IS CO NTA
HO URS PER DAY, 7 DAY S PER WE EKRLD, YOU ’LL
WH ERE VER YOU ARE IN THE WO
ING LIN E
BE ABL E TO ACC ESS THE LIS TENTEL EPH ON E CAL L SER VIC E
NIS E WH ICH
THE LIS TEN ING LIN E WIL L REC OG
FRO M, AN D
CO UN TRY YOU ARE CAL LIN GSO ME ON E
ENS URE THE CAL L IS HA ND LED BYE
WH O SPE AKS THE RIG HT LAN GU AGANON.

ND LED BY
YOU R CO NC ERN S WIL L BE HAWIT HOR GA NIS ATI ON
IND EPE ND ENTANERI NG YOU
SPE CIA LIS T CAL L HA ND LER S, OFF
THE HIG HES T LEV EL OF PRI VACYYOU HAV E THE OP TIO N TO CAL L OR
YOU

24/7

016

ARE

ABL E

TO REM AIN
IF YOU WIS H

ACCESSIBLE

GLOBALGO ON LIN E

AN ON YM OU SPRIVATE

Speaking up doesn’t always feel easy to do, but with the Listening
Line, we want to create a route for you to raise any issues that you
can feel really confident in using. If there’s something you wantto talk about, and you don’t feel you can speak to anyone within
BrewDog about it, the Listening Line is there for you.
Call or go online any time, wherever you are in Planet BrewDog.
Details of the Listening Line can be found on Huddle in the Benefits& Wellbeing section.

017

BREWDOG

HUMAN RIGHTS EQUALITY AND DIVERSITYHUMAN
RIGHTSEQUALITYAND
DIVERSITY

018

WE ALL NEED TO ENSURE THAT EVERY CREW
MEMBER, CUSTOMER, SUPPLIER OR ANYONEELSE WE WORK WITH, IS TREATED IN A FAIRAND UNBIASED WAY. ANY DECISIONS WE MAKEMUST
BE
OBJECTIVE,
FREE
FROM
ANY
PRE-CONCEIVED IDEAS AND BASED SOLELY ON
BUSINESS REASONS.

We must all treat every crew member, customer, supplier or anyone
else with whom we work with respect. Treat everyone in the way
you’d like to be treated while respecting their individual needs andpreferences.
We must not make any decisions, or treat anyone unfavourably,
because of their personal characteristics including their age,gender, race, nationality, ethnicity, religion or belief, sexual
orientation, whether they have any form of disability or mental
health problems, if they’re pregnant or on parental leave, or any
other way in which they might be perceived as being different
from you.

019

BREWDOG

WORKPLACE BEHAVIOUR

WE WANT TO CREATE A WORKPLACE WHEREOUR CREW FEEL COMFORTABLE AND SAFE
WHEN WORKING FOR US. WE NEED TO CREATE
AND MAINTAIN AN ENVIRONMENT WHERE
EVERYONE CAN WORK IN SAFE, HEALTHY AND
PRODUCTIVE WAY.

SHOWINGRESPECT TO YOURMEANS YOU WILLCOLLEAGUESNEVERUSE PHYSICAL OR VERBAL ABUSE OR THREATSWORKPLACEBEHAVIOURIF YO UB E L IE V
E T H ATYO U OR YO UMEMBERS AR R CREW
E N ’T B
T R E ATE IN GED W
TA L K T IT H R E S P E C
T,OYO U RM A N AGL IN EER OR
A N OT H
PERSO
ER
N RE
F O R YO S P O N S IB L E
T H E F IR U R A R E A IN
S T IN S
TA N C E.

020

SHARE OFFENSIVE, DEROGATORY OR SEXUALLY
EXPLICIT MATERIALS BY ANY COMMUNICATIONTOOL INCLUDING, BUT NOT LIMITED TO, EMAIL,TEXT SERVICES, THE INTERNET OR SOCIAL MEDIA
MAKE OFFENSIVE OR DEROGATORY JOKES ORCOMMENTS (EXPLICIT OR BY INNUENDO)
ENGAGE IN SEXUAL OR PHYSICALHARASSMENT OR BULLYING
USE ANY UNWELCOME BEHAVIOURTOWARDS ANYONE

EVER
O
A LS
CA N T H E
UYO TACTNE .
CON NING LIE
L I ST

021

BREWDOG

SAFETY AT WORKSAFETYAT WORKWE ARE COMMITTED TO OPERATING A SAFEWORKPLACE FOR OUR CREW. WHETHER YOU
WORK IN ONE OF OUR BREWERIES, WAREHOUSES,OUR BARS, OUTPOSTS OR DOGTAPS, WE WILL
GIVE YOU THE TRAINING AND INFORMATION YOU
NEED TO KEEP YOURSELVES, YOUR COLLEAGUESAND OUR CUSTOMERS SAFE.

We’ll make sure you have everything you need to keep
yourself and your working environment safe, but if you’re
not sure about anything, check with your line manager. As
well as our policies and procedures, there are a numberof important laws and regulations that affect how wework. If you need more information on anything to do withhealth and safety while at work, it’s crucial that you take alook at our Health and Safety policy and talk to your line
manager.
An important part of keeping a safe working environment
is working without the influence of alcohol, illegal drugs
or other substances that might alter your judgement andabilities. If you’re aware of any behaviour like this thatmight cause a safety or environmental hazard, please
help us eradicate it by telling your line manager or call the
Listening Line straightaway.
We LOVE beer, but if you’re working or on shift, other than
our usual quality control tasting requirements, please wait
until after work to enjoy our beer in a responsible way.
We have a zero tolerance policy toward any form of
aggressive or violent conduct in our workplace, and that
includes colleagues, customers, or any other third parties
who work with us across our business.
The Health & Safety Executive (HSE) define work-related
violence as “any incident in which a person is abused,threatened or assaulted in circumstances relating to theirwork. This can include verbal abuse or threats as well as
physical attacks”. While there is no universally accepted
definition of ‘unacceptable behaviour’, we share someexamples overleaf.

022

023

BREWDOG

SAFETY AT WORKUNNACCEPTABLE BEHAVIOUR
OFFENSIVE OR ABUSIVE LANGUAGE, VERBAL ABUSEAND SWEARING INCLUDING SPECIFIC REFERENCES TOHOMOPHOBIA, BIPHOBIA AND TRANSPHOBIA (WHETHER AIMEDAT OR CONDUCTED BY EITHER CUSTOMERS OR CREW);ANY PHYSICAL VIOLENCE TOWARDS ANY CREW MEMBEROR CUSTOMERS SUCH AS PUSHING OR SHOVING;
RACIAL ABUSE AND SEXUAL HARASSMENT;PERSISTENT OR UNREALISTIC DEMANDS THATCAUSE STRESS TO CREW MEMBER;
UNWANTED OR ABUSIVE REMARKS;NEGATIVE, MALICIOUS OR STEREOTYPICAL COMMENTS;
INVASION OF PERSONAL SPACE;
BRANDISHING OF OBJECTS OR WEAPONS;
NEAR MISSES I.E. UNSUCCESSFUL PHYSICAL ASSAULTS;
THREATS OR RISK OF SERIOUS INJURY TO
A CREW MEMBER OR CUSTOMERS;We all have responsibility for our own safety and that ofour colleagues at work and we urge all employees to be
familiar with policies and procedures and precautions to
reduce the risk of physical or verbal abuse. We encouragecrew to participate in relevant training where provided
and to both report all incidents of abuse (threatened or
actual) and record details of any incidents. Crew should
also contribute to managers reviewing incidents in which
they have been involved and suggest precautionary
measures including changing to working practices thatmight reduce risks.
Managers will carry out appropriate risk assessments,
identify any ‘at risk’ situations and take steps to reduce orremove risks to crew where practicable. We take a serious
view of any incidents of aggression or abuse against ourcrew and will support them if assaulted, threatened or
harassed. Managers will also assist victims of violencewith the completion of the formal record of the incident
and where appropriate will report the incident to the police.

UNSUBSTANTIATED, VEXATIOUS OR DEFAMATORYALLEGATIONS ABOUT OUR CREW;
BULLYING, VICTIMIZATION OR INTIMIDATION;STALKING;
ALCOHOL OR DRUG-FUELLED ABUSE;UNREASONABLE BEHAVIOUR AND NON-COOPERATIONSUCH AS REPEATED DISREGARD OF COMPANY POLICIES.

It’s important to remember that such examples of behaviour set out
above can be either in person, by phone, letter, email, social media
or any other form of communication. This policy applies throughout
our business. It also applies to any crew member away from our
premises but only in so far as it relates to our business.

024

If an incident occurs, it is important for all details tobe recorded accurately and factually so that a fullinvestigation can be completed (if necessary) and we cantake appropriate action. The appropriate response to an
incident will depend on the individual circumstances ofeach case. Action should be taken where aggressive or
abusive behaviour is likely to prejudice the safety of crew,
where a crew member fears for their safety, where othercrew or customers safety may be prejudiced or where
there is a risk of damage or harm to persons or property.

025

BREWDOG

SAFETY AT WORK

TAKINGACTIONIN
TH E
FIR ST
INS TAN CE
A
CR EW
ME MB ERSH OU LD AS K TH E PE RP ET
RATO R TO STO P BE HAVINGIN AN UN AC CE PTA BL E WA
Y. SO ME TIM ES A CA LM AND
QU IET AP PR OACH WIL L
BE AL L TH AT IS RE QU IRE
D.
CR EW SH OU LD NO T IN AN
Y CIR CU MS TAN CE S RE SP ON
D
IN A LIK E MA NN ER .
SH OU LD TH E PER SO N NO
T STO P TH EIR BE HAVIO UR,
A MA NAGE R SH OU LD
BE AS KE D TO JO IN
TH E
CO NV ER SAT ION AN D TH E CR
EW ME MB ER SH OU LD EX PLAINCA LM LY WH AT HA S TAK EN
PLACE , PR EFE RA BLY WIT HIN
HE AR ING RA NG E OF TH E PER
PET RATO R.
IF TH E PE RS ON IS AC
TIN G IN AN UN LAW FU
L
MA NN ER , CA US ES DA MAGE OR AC TU AL LY ST RIKESAN OT HE R PE RS ON TH EN
TH E PO LIC E SH OU LD BE
CA LLE D IMM ED IAT ELY.

WHAT TO DO
IF VIOLENCE& AGGRESSIONIS ENCOUNTERED
026

IF A CU STO ME R BE HAVES IN A RU DE , OF FEN SIV
E,
AB US IVE OR INT IMI DATING MA NN ER TH EN OU R CR
EWHAVE TH E RIG HT TO RE MO
VE TH EM FR OM TH E PR EM
ISE S
US ING RE AS ON AB LE ME AS
UR ES ; IF TH EY RE FU SE , THEN
CA LL TH E PO LIC E IMM ED IATELY.
SH OU LD IT PR OV E NE CE SS
AR Y TO RE MO VE A CU STO MER
FR OM TH E PR EM ISE S TH
EN TH OS E CR EW ME MB ERSINV OLVE D MU ST CO MP LET
E A WR ITT EN NO TE OF TH
E
INC IDE NT, DE TAI LIN G IN CH
RO NO LO GIC AL OR DE R WH
AT
HA S TAK EN PLACE .
EV ER Y ATT EM PT SH OU LDBE MA DE TO DE -ES CA LAT
E A
SIT UATIO N TH AT CO UL D PO
TE NT IAL LY BE CO ME AB US
IVE
OR WO RS E.

027

MEDIACODESOCIAL
OF CONDUCTBREWDOG

SOCIAL MEDIASOCIAL MEDIA IS A LARGE PART OF LIFE, AND WE
UNDERSTAND THAT MANY OF OUR CREW ARE ACTIVE
ON SOCIAL MEDIA, SOME WITH ACCOUNTS LINKED TO
THEIR ROLES IN BREWDOG, AND OF COURSE THROUGHPERSONAL ACCOUNTS.
WE HAVE ALWAYS SUPPORTED POSITIVE USE OF
SOCIAL MEDIA AND IT’S BEEN A PART OF OURMARKETING STRATEGY SINCE WE STARTED OUR
BUSINESS, BUT WE ALSO REALISE THAT SOCIAL MEDIACAN BE CHALLENGING AND CAN LEAD TO UNINTENDED
NEGATIVE CIRCUMSTANCES ARISING.

We expect all of our crew with social media accounts in any way
linked to BrewDog to act in a responsible and ethical manner when
posting on, or otherwise using, social media. If your account is
not linked to your role in BrewDog, if it is clear that you work for
BrewDog in your profile information, then that connection should
be considered when conducting yourself on social media. You
should always ensure that it’s clear that anything you post is yourown views, and you are not representing the views of the business.

028

DI A,
WH EN US IN G SO CI AL MEGOW IN IN MI ND:
PL EASE KE EP TH E FO LL
EN
D CO MM ON CO URTESY WH
US E CO MM ON SE NS E AN
DIA
ME
L
CIA
R PEO PLE ON SO
INT ER ACTIN G WIT H OT HE
WH ICH IS CO NF IDE NT IAL
DO N’T PO ST AN YT HIN G,
AN Y OF OU R CU STO ME RSTOTO OU R BU SIN ES S OR
.
RS
LDE
KE HO
SU PPL IER S, OR OT HE R STA
RACIST, SE XIST,
DO N’T US E OF FEN SIV E,
LAN GUAG E.
OR OT HE R DE RO GATO RY
TIN G
NC E BE FO RE PARTIC IPA
YO U SH OU LD SE EK GU IDA
ED
SS
CU
DIS
ING
TH E TO PIC BE
IN SO CIA L ME DIA WH EN
ISIS
CR
A
.
(E.G
E
ITIV
NS
MAY BE CO NS IDE RE D SE
AL PR OP ERTY, ISS UE S
SIT UAT ION, INT ELL ECTU,BR EW DO G’S RE PU TAT ION
WH ICH MAY IMPACT ON
).
IAL
TER
MA
E
CO MM ER CIA LLY SE NS ITIVAR OU NDSO CIA L ME DIA ACTIV ITY
RE FER RE DBELDOUSE NS ITIV E TO PIC S SHETI NG .
RK
MA
OF
R
TO
EC
TO OU R DIR

UR ITY TH RE ATS AN D
PLE AS E BE AWAR E OF SEC
EN GIN EER ING AN DLCIA
BE ON GUAR D FO R SO
O
CIA L NE TWOR KS CA N ALSPH ISH ING ATT EM PTS. SO
E.
AR
LW
MA
D
AN
M
SPA
BE US ED TO DISTR IBU TE
AN ON YM OU SLY OR
AVO ID PO STI NG ON LIN EU SH OU LD NE VE R
US ING PS EU DO NY MS. YO
IND IVID UA L.
IMP ER SO NATE AN OT HE R

029

BREWDOG

SOCIAL MEDIA

If someone’s use of social media is considered to be derogatory,
discriminatory, bullying, threatening, defamatory, offensive,
intimidating, harassing, creating legal liability for BrewDog, bringing
the business into disrepute, then we may be required to take action
under the staff disciplinary procedure. This may include comments,
videos, or photographs, which have been posted on social media
sites about BrewDog, crew members or other stakeholders. We will
always ensure that any action we take in response to any misuseof social media in a personal capacity will be reasonable andproportionate to the perceived offence; the nature of the postings/
comments made and the impact or potential impact on BrewDog. We
may require you to remove social media postings which are deemed
to constitute a breach of this code and failure to comply with such arequest may, in itself, result in disciplinary action.
It should go without saying, but we’ll say it anyway, that crew
members should not engage in illegal activity through social media
or engage in any activity that promotes criminality or terrorism.

IF YO U B EC O
M E AWA R E O
A N Y T H IN G OFN S O C IA L M E
D IA W H IC H
YO U T H IN K M
IG H T B E DA M
AG IN GTO O U R B U S
IN E S S O R TO
ANY OFO U R C R E W, P
L E AS E F L AG
T H IS TOO U R D IR ECTOR OF MARKE T IN G
OR USE THE
L IST E N IN G L
IN E .

030

LET’S ALL
TRY&
USE
SOCIAL MEDIA
AS A
FORCE
FOR
GOOD
031

BREWDOGRECRUITMENT
WE WANT TO ATTRACT AND RETAIN THE BESTPEOPLE, AND WE WANT OUR PEOPLE TO ACHIEVE
THEIR BEST WHEN THEY WORK FOR BREWDOG.
All of our decisions about recruitment, hiring, development andpromotion should be made on ability, skills, experience, behaviour,
performance and potential to do the job. All of our roles will beaccessible to candidates from all backgrounds and across a broad
range of experience.
By employing the best people and creating an environment inwhich they can grow and develop, we’ll achieve our goals including
our strong desire to build exceptional crews.
Your line manager is always there to listen to any suggestions
or issues you might have. They’ll also talk to you regularly about
how you’re getting on and how the business can help with yourpersonal development. If you have any concerns about the way
recruitment and selection is being conducted, please contact ourPeople Director or the listening line.

032

WORKPLACE CODECOMPLIANCE

WITH

LAWS

ALTHOUGH BREWDOG OFTEN CHALLENGE THE
STATUS QUO, WE WILL ALWAYS ACT WITHIN THE
LAWS OF THE COUNTRIES IN WHICH WE WORK.
THERE ARE STRICT CONTROLS ACROSS THE GLOBE
FOR BUSINESSES INVOLVED IN THE PRODUCTION
AND SALE OF ALCOHOL, AND WE ADHERE TO
ALL OF THOSE RULES & REGULATIONS. WE ALSOENSURE THAT ALL HEALTH, SAFETY & WELLBEINGLAWS ARE STRICTLY COMPLIED WITH; WITHOUTEXCEPTION.
We engage in the international movement of alcohol and otherproducts to carry out our business. We follow all applicable importand export laws associated with these activities, and we do not
conduct unauthorised business with countries or third parties thatare subject to trade sanctions.

033

BREWDOGSUSTAINABILITY AND ENVIRONMENTSUSTAINABILITYAND
ENVIRONMENTBREWDOG IS A FULLY CARBON NEGATIVE
BUSINESS. WE DOUBLE OFFSET OUR SCOPE 1, 2
AND UPSTREAM SCOPE 3 CARBON; THIS MEANS
WE ALSO INCLUDE ALL OF THE CARBON IN OUR
SUPPLY CHAIN TOO.

O U R A P P R OAC HOUR“The concept of sustainability is based on the premisethat people and their communities are made up ofsocial, economic, and environmental systems that are in
constant interaction and that must be kept in harmony
or balance if the community is to continue to function to
the benefit of its inhabitants — now and in the future.

APPROACHTO

A healthy, balanced society (or nation, or community,
depending on the strength of one’s magnifying glass) is
one that can endure into the future, providing a decent
way of life for all its members—it is a sustainable society.
Sustainability is an ideal toward which to strive and against
which to weigh proposed actions, plans, expenditures,and decisions. It is a way of looking at a community ora society or a planet in the broadest possible context, inboth time and space”

SUSTAINABILITY(Natural Hazards Centre, 2019).

Being Carbon Negative is great, but that doesn’t mean that we
can’t still work hard on reducing our consumption of resources,and our crew should always strive to reduce, reuse and recycle.

034

035

BREWDOGSUSTAINABILITY AND ENVIRONMENT

We therefore ask ourselves some basic questions in making workbased choices to live by our own ethics in seeking to reducecarbon emissions e.g.

We should always aim to reduce our environmental impact in
how we conduct our business, and how we conduct ourselves
within our business. If there’s a lower impact way of doing
something, then we should strive to do that if the impact on
our business is, on balance, positive.

WILL VIRTUAL MEETINGS SAVE ENERGYAND CARBON AND MEET THE BUSINESSNEED TO ENGAGE EFFECTIVELY?

If any crew member thinks there’s something we can do better,and in a more sustainable way, please raise it with your line
manager and we will listen. We are always looking at how we
can reduce our carbon emissions and we need every crew
member to get onboard with this.

IS IT POSSIBLE TO TRAVEL TO MEETINGSAND EVENTS BY WALKING, CYCLING,
USING PUBLIC TRANSPORT?

We are committed to being a Carbon Negative business, andour Make Earth Great Again reports set out in full what we aredoing to reduce and offset double the amount of carbon weemit as a business.

IS IT POSSIBLE TO MINIMISE THE NEEDTO FLY AS A MEANS OF TRANSPORT
WHEN CONDUCTING OUR BUSINESS?
IF WE NEED TO DRIVE, CAN WE
DRIVE IN A WAY WHICH MINIMISESFUEL CONSUMPTION?
CAN WE MAKE DIETARY CHOICES AT
WORK WHICH ARE LOW CARBON I.E.,
LOCAL AND ETHICALLY SOURCED?

PLEA
SE M
YO U
AK
R
GREA EAD THE E SUREM
T AG
AIN R AKE EAR
FA M IETH
P O RTLIARI
WITH
O U R S E YO U R S A N D
SELF
S
G OA
LS A U STA I N A
ND A
BILIT
CT I VITIES Y.

CAN WE MINIMISE THE NEED TO
PRINT USING PAPER IF FILES AREHELD ELECTRONICALLY?

036

037

BREWDOG

WORKPLACE CODE

MODERNSLAVERY ACTCOMPLIANCE
AND
ETHICAL
SUPPLY
038

AT BREWDOG WE ARE COMMITTED TOETHICAL CONDUCT AND COMPLIANCE
WITH
LAWS
PROHIBITING
HUMAN
TRAFFICKING AND SLAVERY. THE UK
MODERN SLAVERY ACT 2015 DEFINES“MODERN SLAVERY” AS INCLUDING THE
OFFENCES OF “SLAVERY, SERVITUDE AND
FORCED OR COMPULSORY LABOUR” AS
WELL AS “HUMAN TRAFFICKING”, ALL OF
WHICH ARE DIRECTLY OPPOSED TO THE
VALUES AND ETHICS OF OUR COMPANY(AND FRANKLY, ALL COMPANIES WE WANT
BE ASSOCIATED WITH). WE WANT OUR
COMPANY TO BE A FORCE FOR GOOD AND
WILL ALWAYS ENSURE THAT THERE ARE
ABSOLUTELY NO HUMAN TRAFFICKINGANDFORCEDLABOUR
ACTIVITIESANYWHERE WITHIN OUR ORGANISATIONOR OUR SUPPLY CHAIN.

BrewDog purchases the highest quality goods and services
from suppliers all over the world, while trying to purchaselocally as much as we can. BrewDog will only ever do businesswith awesome suppliers who believe in things we believe inand as part of us selecting who we work with we always makesure that they are fully compliant with all anti-slavery andhuman trafficking laws in the countries in which they operate.
We fully expect them to have suitable anti-slavery and humantrafficking policies and processes in place, all of which forms
part of our New Vendor process when we onboard new
suppliers. If an organisation doesn’t make the cut, then we
won’t work with them. Ever.

039

BREWDOG

BrewDog expects its key suppliers to follow the Corporate Codeof Ethics published by CIPS (Chartered Institute of Procurement
and Supply). The Code sets out the values, business culture andpractices which all organisations can adopt. The Code requires acommitment to the eradication of unethical business practices,
including bribery, fraud, corruption and human rights abuses, suchas modern slavery and child labour.
BrewDog does not and will never use child forced labour, we have azero-tolerance approach to anyone who does. If BrewDog uncovers
any evidence of forced labour within a supplier or potential
supplier, we shall immediately cease conducting business withthem. If we find evidence of child forced labour, we will ensure a
remediation plan is put in place to ensure the eradication of thatchild forced labour.
BrewDog does not allow or condone physical punishment orabuse, again here if we uncover any evidence within a supplier or
potential supplier we shall immediately cease conducting businesswith them.

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WORKPLACE CODE

RECORDS &INFORMATIONAS A GLOBAL GROUP OF COMPANIES, OUR
BUSINESS MUST FOLLOW AND ADHERE TO MANYREGULATORY PROCESSES AND RULES. FROM HOW
WE MANAGE DATA TO SUBMITTING ACCURATEACCOUNTING RECORDS, IT’S ALL IMPORTANT
INFORMATION TO READ AND TAKE IN. THERE’S A
LOT TO REMEMBER, THOUGH, SO IF YOU’RE EVER
UNSURE, CHECK WITH YOUR LINE MANAGER.

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WORKPLACE CODEWE SHOULD LOOK AFTER OUR PROPERTY AS IF IT
WERE OUR OWN; WE SHOULD USE IT CAREFULLYAND PROTECT IT FROM ANY MISUSE.

COMPANYPROPERTY
We all use company property in order to carry out our jobs. This
includes tangible things like buildings, vehicles, equipment supplies,
computers, networks, e-mail and voicemail systems. Likewise, aspart of our jobs, we’ll create or develop more specialised things likebeer recipes, new spirits, brands, trademarks and designs, as well as
having access to important business information. All of these things– physical or not – are company property and we need to protect
them from misuse.
Please look after all company property as if it were your own. We
understand that from time to time our crew may use company
equipment to access the internet for personal reasons but we should
always protect it from misuse. You should not use our company
assets for an outside business or for anything illegal or unethical.

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ACCOUNTING
RECORDS
HONEST AND ACCURATE RECORDS HELP OUR
CREW AND OTHER STAKEHOLDERS ASSESS THE
FINANCIAL STABILITY AND PERFORMANCE OF THE
BUSINESS. THEY’RE ALSO A LEGAL REQUIREMENT.

Creditors, government officials, partners and people from acrossour business all need to access books, records and statements
about our financial performance. These must give fair and accurate
information and be protected from unauthorised viewing, damage
and loss. It’s important that you keep all documents safely and forthe right length of time.
All people who work regularly with our reports and records need tofollow our guidelines and procedures. If you’re unsure of anything,always check with your line manager.

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INFORMATION &DATA SECURITY

WORKPLACE CODE

we must take particular care when dealing with sensitive personal
data. We need to be very careful that we only retain personal data
for as long as necessary and/or permitted and it is important toensure that all personal data is managed or handled in line withthe permissions given by the individual to whom the data relates.
Where any personal data has been accessed, shared or usedwithout permission or you are aware of any other incident involving
personal data, please contact privacy@brewdog.com asap in orderthat this can be addressed, or contact the Listening Line.
Please be aware of where you are when you’re discussing or
working on company matters to ensure that you are not unwittingly
disclosing confidential information in public.

WE SHOULD KEEP ALL COMPANY INFORMATIONSAFE AND SECURE. WE MUST AVOID SHARING
COMPANY INFORMATION OUTSIDE OF THE
BUSINESS, AND WE SHOULD PROTECT OURTECHNOLOGY AND DATA IN THE SAME WAY WE
WOULD PROTECT OUR PERSONAL DATA.
We must respect everyone’s privacy and ensure that we process all
personal data in compliance with applicable data protection laws.
Please ensure that you familiarise yourself with the BrewDog Staff
Privacy Notice, Data Protection and Information Security Policies
Data protection laws regulate how we collect, use and manage
personal data (such as names, addresses, dates of birth, national
insurance numbers, passport numbers and any data which canidentify a living individual). Of course, this data doesn’t just relate
to customers but also, and just as importantly, it can be information
about our crew, suppliers and partners.

WHEN WE TALK ABOUT CONFIDENTIAL
INFORMATION WE’RE REFERRING TO THINGS LIKEFINANCIAL INFORMATION, BUSINESS PLANS, BUSINESSSTRATEGIES, BUSINESS PRACTICES AND RELATIONSHIPS,PROCESSES, SYSTEMS OR METHODS OF OPERATION;

SPECIFICATIONS, PRICING POLICIES, MARKETING
PLANS, COSTS OR PROMOTIONAL ACTIVITIES;INFORMATION RELATING TO CUSTOMERS,SUPPLIERS AND PARTNERS.

We must protect personal data and keep it secure and in addition,

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BREWDOGCOMPETITIONCOMPETITION LAW IS DESIGNED TO ENSURE THAT
BUSINESSES ARE COMPETING FAIRLY AND ARE
PROTECTED FROM OTHERS ACTING UNFAIRLY.
IT’S UNLAWFUL FOR COMPETING BUSINESSES TO
MAKE ARRANGEMENTS AMONG THEMSELVES THAT
COULD UNDERMINE OPEN AND FAIR COMPETITION
OR DISADVANTAGE CUSTOMERS.

WORKPLACE CODE

We deal honestly and fairly with our suppliers, customers, consumers
and government entities and never take unfair advantage of anyone
by misleading or deceiving them. We don’t make claims we cannot
substantiate and do not make inaccurate statements about ourcompetitors or their products.
Bear in mind that arrangements don’t have to be in writing in orderto break the law; they can be agreed in a meeting, at an event or ona phone or video call. All of us need to take great care when dealing
with customers, or competitors, whether as part of their role or in asocial context.
Obtaining information about our competitors is normal best practice
but make sure it is obtained fairly and not in breach of confidence.
You should not gather or ask someone else to gather information
using any illegal or illicit activity.

Non-compliance with competition law could have extremely
serious consequences for our business, including significant
financial penalties and legal claims from competitors andcustomers, as well as the resulting damage to our reputation. For
any individuals who break the law, this may result in imprisonment
and fines, and disqualification from managing a business.

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WORKPLACE CODEGIFTS &HOSPITALITY
WE NEED TO ENSURE THAT ANY GIFTS ANDHOSPITALITY RECEIVED DURING THE COURSE OF
OUR WORK ARE REASONABLE AND DON’T
IMPROPERLY INFLUENCE OUR JUDGEMENT OR
DECISION-MAKING. IF WE’RE UNSURE ABOUTACCEPTING ANY GIFT OR HOSPITALITY, WE SAY NO.

Hospitality includes invitations to social functions, sporting events,
meals and entertainment. Any gifts or hospitality should always becustomary and reasonable in terms of value, frequency or timing,and must be approved by your line manager. It is also importantthat we never request gifts, meals, entertainment or favours fromthese third parties.
We aren’t saying you should never accept gifts, but you shouldbe open and honest about why you’re being offered the gift, andyou should inform your line manager. If the gift seems to bedisproportionately large or lavish, then you must decline.
Sometimes people working directly with customers are offeredtips for their services. Receiving tips from customers for doing
your job well is fine, but please don’t ask for tips. Tips must becompletely voluntary.

We all deal with customers, suppliers or other third parties withwhom we do business on a regular basis. If you’re offered a gift,
hospitality or other benefit from one of these companies, you must
inform your line manager, as it could place you or our business inan awkward position when it comes to making business decisions.
Gifts can be seen as a form of persuasion to make you do something
you shouldn’t, like awarding a contract or doing something for the
person who makes the offer which you wouldn’t otherwise do.

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WORKPLACE CODEANTICORRUPTIONTHEFTWE MUST NEVER GIVE OR ACCEPT A BRIBE OR
PARTICIPATE IN DISHONEST PRACTICES. IT
CAN SERIOUSLY DAMAGE OUR REPUTATION.
IT’S BETTER TO MISS OUT ON A BUSINESSOPPORTUNITYTHAN
COMPROMISEOURINTEGRITY AND HIGH STANDARDS.

IF IT
PROPERT Y AS
R
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R
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T
F
A
P LE A S E LO O KN.
W E R E YO U R O W
IS TA K IN G
AU D O R T H E F T
R
F
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OUR
IF YO U B E LI
YO U TA LK T O Y
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P LAC E , IT ’S IM P
T T H E LI S T E N IN
C
TA
N
O
C
R
O
R
LI N E M A N AG E
S T R A IG H TAWAY.

A bribe involves the promise of anything of value to influence
someone’s behaviour so they don’t perform their role properlyor so that they provide a benefit to our business. This can takethe form of money, a gift or a favour. It’s important that our crew
never give or accept bribes. Please also make sure that third
parties working on our behalf understand that we don’t approveof giving or accepting bribes.
Likewise, our crew must not get involved in any dishonest
practices, including activities such as fraud, deception or
collusion.

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WORKPLACE CODE

MONEY LAUNDERING IS A PROCESS WHERE FUNDS
GENERATED THROUGH CRIMINAL ACTIVITY – SUCHAS TERRORISM, DRUG DEALING, TAX EVASION,HUMAN TRAFFICKING AND FRAUD ARE MOVED
THROUGH LEGITIMATE BUSINESSES IN ORDER TO
HIDE THEIR CRIMINAL ORIGIN.

TAX EVASIONMONEY
LAUNDERINGWE’RE FIRMLY COMMITTED TO MEETING ALL OF
OUR STATUTORY TAX OBLIGATIONS, WHEREVER IN
THE WORLD THEY MIGHT ARISE. WE HAVE A ZEROTOLERANCE POLICY TO THE FACILITATION OFTAX EVASION.
“Tax evasion” means fraudulently evading or cheating a tax authorityof the tax it is lawfully owed. Tax evasion is a crime and we canbe criminally liable for acts committed by an employee, agent or
consultant which facilitate others to evade tax. If tax evasion takes
place, a business could face an unlimited fine as well as criminal
convictions.
If a supplier has asked you to do something unusual, this may require
further investigation as it may involve tax evasion.
Please speak to your line manager straightaway and if in doubt,
please contact our Chief Financial Officer or the Listening Line.

052

We take the time to get to know our business partners by performing
appropriate due diligence and screening.
Payments to business partners should be made only to the person
or company that actually provides the goods or service in a country
where the supplier has sold goods or provided services to ourbusiness.
We will not transfer payments to or accept payments from entities orcountries not related to the transaction giving rise to the payment.
If you are concerned about any financial transaction or proposed
payment which looks suspicious or is outside of normal process,contact our Chief Financial Officer or the Listening Line.

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WORKPLACE CODE

SUMMARY
THIS WORKPLACE CODE SHOULD
REFLECT OUR VALUES AND CULTURE,
AND IT WILL BE REVIEWED AT LEAST
EVERY YEAR TO MAKE SURE IT IS
CURRENT, VALID AND UP TO DATE.

054

THE
DIRECTORSWILL REVIEW AND
SIGN OFF ANYAMENDMENTS TO
THIS DOCUMENT AND
ANY CHANGES WILL
BE COMMUNICATEDTO OUR CREW
THROUGH HUDDLE.

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