Asahi Group Global
Supplier Code of
Conduct

Table of Contents
1.

The Asahi Group Global Supplier Code of Conduct ......................................................... 42.

Application and scope ...................................................................................................... 5

3.

Business integrity ............................................................................................................. 5

4.

Human rights and labor standards ................................................................................... 6
4.1

Child labor ................................................................................................................ 7

4.2

Forced and compulsory labor .................................................................................... 8

4.3

Discrimination and harassment ................................................................................. 8

4.4
Safe and decent work conditions .............................................................................. 8
Safe and decent accommodation ................................................................................... 8
Hazardous materials ........................................................................................................ 9
4.5

Responsible recruitment ........................................................................................... 9

4.6

Fair wages .............................................................................................................. 10

4.7

Working hours......................................................................................................... 10

4.8

Women’s rights ....................................................................................................... 11

4.9

Freedom of association and collective bargaining ................................................... 11

5.

Rights to land and natural resources .............................................................................. 11

6.

Human rights defenders ................................................................................................. 12

7.

Environment................................................................................................................... 12
7.1

Compliance with all applicable environmental laws and regulations ........................ 12

7.2

Reducing environmental impacts ............................................................................ 12

8.

Responsible drinking ...................................................................................................... 13

9.

Information management ............................................................................................... 14

10. Product quality and safety .............................................................................................. 14
11. Origin transparency........................................................................................................ 14
12. Grievance mechanism and remediation ......................................................................... 14
12.1

Prohibition against retaliation .................................................................................. 15

13. Sub-contracting .............................................................................................................. 15
14. Performance monitoring and compliance breaches ........................................................ 15
15. Policy Review ................................................................................................................ 17

Asahi Group Global Supplier Code of Conduct2

Issuing Function /Author
CEO Asahi Global Procurement
Target audience
This Global Supplier Code of Conduct applies to all Suppliers, their officers, employees,
representatives, subsidiaries, agents, contractors, or upstream suppliers (“Associated Parties”)
providing goods or services to Asahi Group, its subsidiaries, or other companies it directly or
indirectly owns or manages. Suppliers include any individual or corporate entity associated with
Asahi Group, or who performs functions in relation to, or on behalf of, Asahi Group.
ApproverGroup CFO Asahi Group Holdings
Date of publication
August 08/2024
Order of precedenceThis Asahi Group Global Supplier Code of Conduct takes precedence at any time over any local
or regional policy, and in case of any differences between any Asahi regional entity and local
entity Procurement policies, the Asahi Group Global Supplier Code of Conduct shall takeprecedence.
Disclaimer
This Asahi Group Global Supplier Code of Conduct provides general guidelines / rules /instructions for all suppliers of Asahi Group worldwide. While comprehensive, it may not cover
all legal requirements in every jurisdiction. Suppliers must comply with this Global Supplier
Code of Conduct alongside local laws and regulations. In case of conflict, local laws takeprecedence. This Global Supplier Code of Conduct is reviewed periodically and may be
updated.

Asahi Group Global Supplier Code of Conduct

3

1.

The Asahi Group Global Supplier Code of Conduct

The Asahi Group (‘Asahi’, ‘we’) is committed to a principled approach to doing business. We
operate in a way that promotes responsibility in the areas of human rights, the environment,compliance, and ethical conduct, and actively discourage corruption and corporate fraud. We
expect our Suppliers to meet the same standard.
Asahi Group includes those group of companies which are direct or indirect subsidiaries orotherwise ultimately owned or controlled by Asahi Group Holdings, Ltd.
A Supplier is any person or entity which provides specific goods and/or services to a member ofthe Asahi Group in connection with the businesses it owns and operates.
The minimum compliance requirements and standards we require from our Suppliers of goods
and/or services form the basis of the Asahi Group Global Supplier Code of Conduct (the‘Supplier Code of Conduct’). To enable accessibility for all of our global Suppliers, please refer toour website for versions of this Supplier Code of Conduct available in multiple languages.
We require our Suppliers to embrace, support, and enact these minimum expectations, andparticipate in ongoing monitoring of their own compliance with this Supplier Code of Conduct.
Suppliers must have evidence of, and adhere to, appropriate policies, management systems,
procedures, and staffing to meet the expectations of this Supplier Code of Conduct.
Asahi expects that its Suppliers communicate this Supplier Code of Conduct to their own
suppliers. Asahi also expects its Suppliers to support their suppliers to meet the expectations
outlined in this Supplier Code of Conduct.
We recognize there will be challenges for Suppliers to meet our expectations and local factorsthat will influence this may vary across our geographically diverse Suppliers. Our expectations
are not limited to compliance with local law, and we are committed to working with our Supplierson continuous improvement in their business practices to meet the standards set out in thisSupplier Code of Conduct. However, subject to compliance with internal processes for the
responsible exit of a Supplier relationship, Asahi reserves the right to discontinue relationships
with Suppliers in circumstances where there is egregious or continued non-compliance with thisSupplier Code of Conduct.
For further information on how we promote responsible business practices in our value chain,
Suppliers can refer to the following Asahi policies and principles:•Asahi Group Human Rights Principles•

Asahi Group Responsible Procurement Policy•

Asahi Group Responsible Procurement – Supplier Guidelines•

Asahi Speak Up Policy•

Asahi Group Environmental Principles

If any person becomes aware of a breach of this Supplier Code of Conduct, either in its own
organization or Asahi’s supply chain, reports can be made to Asahi’s Speak Up channel. This
channel is independently operated by an external party and is available 24/7, 365 days a year, invarious local languages of the countries/regions which we operate in. The Speak Up channel
can be used anonymously and is intended to be confidential. Users may access the Speak Upchannel through one of the following methods:•

Web browser form: asahigroup.ethicspoint.com

•Mobile form: asahigroupmobile.ethicspoint.com•

Free of charge telephone hotline in designated countries/regions (see Asahi Speak Up
Policy – Annex 1 for hotline numbers)

Further details on Asahi’s Speak Up channel are set out in the Asahi Speak Up Policy.

2.

Application and scopeThis Global Supplier Code of Conduct applies to all Suppliers, their officers, employees,
representatives, subsidiaries, agents, contractors, or upstream suppliers (“Associated Parties”)
providing goods or services to Asahi Group, its subsidiaries, or other companies it directly or
indirectly owns or manages. Suppliers include any individual or corporate entity associated with
Asahi Group, or who performs functions in relation to, or on behalf of, Asahi Group.
A copy of this Supplier Code of Conduct will be made available to all Suppliers. The Suppliermust ensure that its Associated Parties and sub-contractors also comply with the principles set
out in this Code. Suppliers are expected to have their own supplier code of conduct or similar
policy that covers the equivalent principles set out within this Supplier Code of Conduct. The
Supplier’s policies should place comparable obligations on its own suppliers. Suppliers shallensure that the expectations outlined within this Supplier Code of Conduct are communicated totheir direct suppliers and be encouraged to pass on the expectations of this Supplier Code of
Conduct throughout their supply chain.
The Supplier, upon entering a contract with Asahi, commits to complying with the Supplier Codeof Conduct for the duration of that contract. This Supplier Code of Conduct defines the minimum
standards that we have committed to and expect our Suppliers to adhere to, or conscientiously
work towards in collaboration with us, whilst supplying goods and/or services to Asahi. It does
not prevent us or our Suppliers from exceeding these standards. In addition to the Supplier Codeof Conduct, Suppliers are expected to comply with national, international, and other applicablelaw within the Supplier’s country of operation. Where the provision of law and this Supplier Codeof Conduct address the same subject, Suppliers must apply the provision that affords the greater
protection.

3.

Business integrity

The Supplier must always act ethically and with integrity, in compliance with all relevant laws andregulations in relation to ethical conduct, corporate fraud, prohibited business practices, and antibribery and corruption, as well as with relevant social norms to the extent that these set a higher
standard for conduct.
The Supplier must commit to the principles of lawful and free competition based on the merits ofproducts and services, and not engage in activities that violate all relevant anti-trust, competition,and consumer protection laws applicable in all the Supplier’s countries of operation.
The Supplier must also maintain full confidentiality of trade information, business processes andtechnology. There must be no infringement on the intellectual property rights of Asahi or thirdparties. Business information (including, but not limited to, employee and technical information)must be thoroughly managed.
Anti-bribery, anti-corruption, gifts, and entertainment
The Supplier must not participate in any form of bribery or corruption, directly or indirectly
through third parties. This means that you never give, receive, seek, engage in, offer, promise or
authorize any bribes to anyone (not only government officials, but also private entities andindividuals). Bribes means anything of value given or received in order to improperly influence
the judgement or actions of others. It is important that the Supplier avoids actions that may giverise to an appearance or suspicion of bribery or corruption, such as the provision of gifts orentertainment that would breach local laws and regulations, or contravene commonly acceptedsocial standards.
The Supplier must mitigate the risk of corruption by having in place an entertainment and gifts
policy that is transparent and culturally appropriate. Gifts and entertainment provided or received
in any way connected to Asahi should not be capable of influencing a person’s duty or authority
and should fall within commonly accepted business practice in each country or region.
Conflicts of interest
The Supplier should avoid situations where a conflict of interest may occur and must promptly
disclose to Asahi any conflicts of interest that do arise. A conflict of interest occurs when aSupplier’s personal or private interests interfere, or appear to interfere, with their ability toperform their duties in the best interest of Asahi. This can include situations where a Supplier
could gain personal advantage, financial or otherwise, from their relationship with Asahi.

4.

Human rights and labor standards

Asahi is committed to respecting internationally recognized human rights as set out in the:•International Bill of Human Rights which consists of the Universal Declaration of Human
Rights (UDHR), International Covenant on Economic, Social and Cultural Rights(ICESCR) and the International Covenant on Civil and Political Rights (ICCPR);•

The United Nations (UN) Guiding Principles on Business and Human Rights;•

The International Labor Organization (ILO) Declaration on Fundamental Principles andRights at Work;•The UN Global Compact;•

The Children’s Rights and Business Principles;•

The Convention on the Elimination of All Forms of Discrimination against Women; and•The International Convention on the Protection of All Migrant Workers and Members ofTheir Families.

Our Supplier Code of Conduct draws on relevant guidance from the:•OECD Guidelines for Multinational Enterprises on Responsible Business Conduct;•

The UN Women’s Empowerment Principles;•

The United Nations Convention on the Rights of the Child; and•The ILO Tripartite Declaration of Principles concerning Multinational Enterprises andSocial Policy

We expect our Suppliers to embrace these international standards, respect the human rights of
their workers and communities and promote human rights within their own value chain.
The requirements of the Supplier Code of Conduct are designed to cover employees, contract
workers and any workers without a formal contract of employment.

4.1

Child labor

The Supplier must not use child labor and must also strictly prohibit the use of child labor in its
supply chain. Child labor, as defined by the ILO, refers to work that deprives children of theirchildhood, their potential, and their dignity, and that is harmful to physical and mental
development. It refers to work that:•

Is mentally, physically, socially, or morally dangerous and harmful to children; and/or•Interferes with their schooling by depriving them of the opportunity to attend school;
obliging them to leave school prematurely; or requiring them to attempt to combine
school attendance with excessively long and heavy work. 1

Subject to the qualifications below, the Supplier must not employ workers below at least 15
years of age, the applicable minimum legal age for employment, or the applicable age forcompleting compulsory education, whichever is highest.2 Any worker under 18 must be
exempted from work which by its nature or the circumstances in which it is carried out is likely tojeopardize the health, safety or morals of the young person. 3
The Supplier must use adequate and verifiable mechanisms for age verification in recruitment
procedures. If the Supplier identifies child labor in their own operations or supply chain, theSupplier must enroll the child/children into a remediation or education program, rather thandismissing them from employment.
If the Supplier identifies that young people are working in hazardous conditions in their own
operations or supply chain, the Supplier must immediately remove the young person/people fromthose working conditions and provide alternative non-hazardous work.
Young people under 18 are entitled to work in certain defined and protected circumstances, suchas traineeships and on family farms where their labor does not interfere with their attendance atschool. This is acceptable as long as it is conducted in line with the requirements of the ILO
conventions and applicable national law in the relevant jurisdictions, and adequate steps aretaken to ensure that it does not interfere with the health, schooling or personal development of
the young person.

1 International Labour Organization (ILO), 2016 ‘What is Child Labour’2
3

As stipulated in the ILO Minimum Age Convention 1973 (No.138), Article 2
As stipulated in the ILO Minimum Age Convention 1973 (No.138), Article 3

4.2

Forced and compulsory labor

The Supplier must prohibit and must not knowingly benefit from any form of modern slavery
whether in the form of forced or compulsory labor, prison labor, indentured labor, bonded labor,
slave labor, or any other non-voluntary labor. This expectation to not use or knowingly benefit
from slavery extends to the Supplier’s entire value chain.
The Supplier must not participate in the trafficking of people and prohibit trafficking throughout
their supply chain. This includes directly or indirectly arranging or facilitating the travel of anotherperson with a view to that person being exploited.
Workers must be free to leave their employment after reasonable notice, and be free to leave
work and/or employee provided accommodation without restriction at the end of their daily shift.
The Supplier must not restrict workers’ freedom of movement or retain workers’ personal
documents including, but not limited to, personal identification, travel documents and bankpayment cards.

4.3

Discrimination and harassment

The Supplier must prohibit discrimination, harassment, sexual harassment, bullying, vilification or
victimization in the workplace, including any harsh or inhumane treatment of workers.
The Supplier must not discriminate against or commit any act that damages the dignity of any
individual based on nationality, race, ethnicity, religion, ideology, gender, age, disability, gender
identity, sexual orientation, political affiliation, union membership, caste, health, pregnancy or
employment status, or any other protected characteristics as defined by national or regional laws
and regulations.

4.4

Safe and decent work conditions

The Supplier must ensure working environments are safe, healthy, and secure, and comply withall health and safety legislation and other relevant obligations while providing employees,
contractors and visitors with information, training, and supervision to understand and upholdhealth and safety responsibilities. The Supplier should regularly identify and assess health andsafety hazards and take action to eliminate or minimize risks.
The Supplier must provide workers with access to potable drinking water and adequate lighting,sanitation, and ventilation. Where appropriate, the Supplier must also provide workers withpersonal protective equipment.
Safe and decent accommodation
The Supplier must ensure workers are free to choose their own accommodation and ensure thatworkers are free to leave any accommodation provided. Accommodation provided to workers by
the Supplier must meet local legal housing standards and, at minimum, be clean, safe and meet
the basic needs of workers. This includes, but is not limited to, a separate bed for each worker,
adherence to international guidelines on minimum room size per occupant, adequate cooking
and sanitary facilities, adherence to fire safety standards, reasonable access to a telephone orother modes of communication and common recreational spaces where not otherwise available

in the community.4 The Supplier must prohibit rental practices that expose workers to excessive
loan repayment programs that disadvantage workers by ensuring rental charges do not costmore than a reasonable portion of the worker’s income.
Hazardous materials
The Supplier must identify hazardous materials and chemicals, and ensure their safe handling,
movement, storage, recycling, reuse, and disposal in compliance with applicable laws andregulations.

4.5

Responsible recruitment

In line with the ILO’s General principles and operational guidelines for fair recruitment, Asahi’s
Suppliers must respect human rights when recruiting workers, including through human rights
due diligence assessments of recruitment procedures, and should address adverse humanrights impacts with which they are involved.
The supplier must:•

Not retain passports, contracts, or other identity documents of workers•

Respect workers’ confidentiality and ensure protection of data pertaining to them•

Ensure that written contracts of employment are provided to the worker, and that thecontract is transparent and understood by the worker•

Ensure that the conditions of work and living conditions into which workers are recruited
are those that they have been promised•

Provide effective access to grievance mechanisms in cases of alleged abuses in the
recruitment process, and to appropriate remedies•

Ensure that the right to freedom of association and collective bargaining of recruited
workers is respected in the recruitment process•

Respect the freedom of migrant workers to leave or change employment or to return totheir countries of origin.

Specifically, the Supplier must ensure that workers do not pay any recruitment fees or othersimilar fees and costs to obtain or retain their employment. This includes the prohibition ofexcessive loan repayment programs that disadvantage workers and may constitute debt
bondage. If the Supplier identifies any instances of workers paying recruitment fees or otherrelated fees or costs, the Supplier must ensure full reimbursement to workers, and promptly
undertake all appropriate remedies and investigate whether any further workers were affected.
Where recruitment agencies or brokers are used by the Supplier, appropriate due diligence andongoing management should be undertaken to ensure that deceptive recruitment practices are
not used. This includes, but is not limited to, the prohibition of mandatory health examinations,pregnancy tests, and the imposition of debt bondage as conditions for employment. Suppliers

4

European Bank for Reconstruction and Development (EBRD) and the International FinanceCorporation (IFC) Workers’ accommodation: processes and standards, Part II, chapter i. Standards forworkers’ accommodation.

must adhere to the responsible recruitment practices, as set out in this Supplier Code of
Conduct, that respect the dignity and rights of all individuals.

4.6

Fair wages

The Supplier must provide employees with fair wages and benefits that, at minimum, comply
with local minimum wage legislation and other applicable wage and working time laws, including
applicable collective bargaining agreements. In countries where the legislated minimum wage is
set below a level consistent with a decent standard of living or dignity for a worker and family,
the Supplier should pay a living wage.5
Employment contracts must clearly state the terms of employment, and workers shall receive a
copy of their terms and conditions of employment in a language they understand for their records
that matches those the employer has on file. This includes information about their employment
conditions before they enter employment and how wages are calculated per pay period.
Remuneration, inclusive of wages and benefits, must be in adherence with all relevant legal
requirements and any binding collective bargaining agreements. This includes adherence toregulations relating to overtime work and other premium pay arrangements.
The Supplier must not make any deductions from wages as a disciplinary measure, or any otherdeductions from wages that are not permitted by the national law without the expressed
permission of the worker concerned.
The Supplier must pay workers directly, regularly, in full and on time in a recognized currency asstated in any worker agreements. Appropriate due diligence must be conducted by the Supplierto ensure these requirements are met when agency workers are used.

4.7

Working hours

The Supplier must ensure that working hours comply with the international standards on working
hours and all applicable laws and regulations related to working hours in the countries where
they do business. Suppliers must also work to limit overtime to ensure workers have adequate
rest periods.
The Supplier shall strive to meet international standards for working hours and rest periods,
including:
(i)
(ii)
(iii)
(iv)

Work weeks of no more than 48 regularly scheduled work hours and 12 voluntary
paid overtime hours,
Overtime hours compensated at a premium rate,
Workers provided one day of rest every 7 days at a minimum, except inemergencies or unusual situations, andNo working more than 21 consecutive days without a rest day.

If a Supplier’s practices do not meet these international working and rest standards, the Suppliermust remedy and improve its practices, and provide remediation to affected workers.

5

As defined in the International Covenant on Economic, Social and Cultural Rights, Article 7.

4.8

Women’s rights

The Supplier must strive to implement measures to eliminate discrimination against women
through providing equal pay for equal work and provide equal opportunities throughout all levelsof employment, in line with applicable laws and regulations.
The Supplier must strive to implement measures to eliminate health and safety concerns that are
particularly prevalent among women workers, in line with applicable laws and regulations. These
concerns include, but are not limited to, sexual harassment, physical security and protection andaccommodation of pregnant and nursing workers.

4.9

Freedom of association and collective bargaining

The Supplier must allow freedom of association and the effective recognition of the right tocollective bargaining in accordance with the applicable laws and regulations of the countries andregions of operations. Suppliers must respect the rights of their employees to choose whether toassociate with a legally recognized labor union, without fear of intimidation, reprisal or externalpressure.
Where the right to freedom of association and collective bargaining is restricted under national orregional laws in contravention of international human rights standards, the Supplier should honor
these rights by establishing alternative means of dialogue with employees.

5.

Rights to land and natural resources

The Supplier must be able to demonstrate legal or customary ownership or land use rights over
all land owned, acquired, or controlled by the Supplier.
The Supplier must respect land ownership and natural resources as set out in The Voluntary
Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests in theContext of National Food Security and International Finance Corporation (IFC) PerformanceStandards on Environmental and Social Sustainability.
The Supplier must respect the rights and title to property and land of individuals, Indigenous
Peoples and local communities in all areas where the Supplier operates. All negotiations
regarding property or land, including the changing use of and transfers of land, must adhere to
the principles of free, prior and informed consent of affected local and Indigenous communities,
contract transparency and disclosure. The Supplier must provide communities access to agrievance mechanism to resolve any disputes over land ownership or use.
The Supplier must conduct all business activities with consideration for the rights of affected
Indigenous Peoples, with recognition for the uniqueness of Indigenous Peoples’ rights, interests,
and traditional relationships to land within and between different regions. The Supplier should
respectfully acknowledge the past, present, and emerging traditional owners and custodians of
the lands on which they operate, with respect for their culture and identity.
The Supplier must respect the right for all individuals to access water.

6.

Human rights defenders

The Supplier must respect the rights of human rights defenders. Any form of abuse, threats,
intimidation, or reprisal against human rights defenders are prohibited.

7.

Environment

In line with the Asahi Group Environmental Principles and Asahi Group Environmental Vision
2050, our objectives include realizing sustainability across our value chain, including managing
the environmental risk and impacts of our business practices.
You can find all of Asahi’s Sustainability commitments on our website: Sustainability | ASAHIGROUP HOLDINGS (asahigroup-holdings.com).
We require our Suppliers to embrace, support, and cooperate towards the goals andcommitments set forth by Asahi Group under the company’s targets in climate change,
packaging, agricultural raw materials, and water resources.

7.1

Compliance with all applicable environmental laws andregulations

The Supplier must comply with all relevant environmental legislation and other relevant
obligations for products or services in relation to environmental performance, management, andreporting.
The Supplier must also ensure policies, procedures, and relevant environmental management
systems are in place to identify, control, and mitigate significant environmental impact, including
ensuring all environmental permits and registrations are legally compliant at any time.

7.2

Reducing environmental impacts

The Supplier will work to provide all necessary and requested information related toenvironmental performance indicators and data at any point during the contractual relationship.
This includes, but is not limited to, data related to climate, packaging, agricultural raw materials,
water resources, deforestation, biodiversity, pollution, waste, and resource management.
For each of the areas outlined below, Suppliers must in a manner consistent with their individual
circumstances and risk:•

Create a management system for regularly monitoring environmental activities.

•

Encourage employees to proactively promote environmental activities and awareness.

•

Engage and collaborate with our teams and stakeholders from our value chain, includingfrom diverse backgrounds and local communities to create and drive environmental

value based on innovation and generate synergies.
Agriculture•

Respect biodiversity and conduct their business activities with consideration tobiodiversity.

•

Avoid deforestation6 during product manufacturing.

•

Actively work on developing and/or using more resilient crop varieties.

•

Use their best endeavors to transition towards regenerative agriculture practices.

•

Use their best endeavors to implement proper land management practices.

Climate change•

Use their best endeavors to use scientifically accepted methodologies to calculate
greenhouse (GHG) emissions, and to set clear and ambitious climate goals.

•

Use their best endeavors to mitigate their direct and indirect emissions, with initiatives todecarbonize their direct and indirect operations, in line with our Net Zero goal set for
2040.

•

Use their best endeavors to publicly report its decarbonization progress in a transparent
manner, where they are required to do so.

•Engage in collaborative efforts with our teams and the teams of our value chain to work
together for climate action.

Water
•

Set targets and plans for water use, measure water use, and improve water use
efficiency.

•

Avoid negatively impacting access to safe water in line with the UN Sustainable
Development Goals and the UN Global Compact’s CEO Water Mandate.

Packaging/waste•

Strive to reduce waste, curb landfill disposal, and promote reducing, reusing, andrecycling of packaging.

•

Develop and promote technologies that reduce environmental impact.

8.

Responsible drinking

The Supplier shall encourage and support responsible alcohol consumption among employees.
Suppliers should recognize that inappropriate alcohol consumption may cause issues such as
drunken operation of a motor vehicle, underage drinking, drinking during pregnancy andbreastfeeding, and binge drinking. Responsible alcohol consumption entails adhering to laws
and local regulations, and consuming alcohol only in safe and appropriate circumstances, while
also promoting moderate consumption from a health perspective. Furthermore, where alcohol
consumption may potentially impact the quality, safety, or reliability of business operations, the6Loss of natural forest as a result of conversion to agriculture or other non-forest land use; conversion toa tree plantation; or severe and sustained degradation. (Natural forest refers to primary forests or foreststhat have regenerated after primary forests have been destroyed by logging, wildfires etc).

Supplier is required to promote and support employees in taking responsible actions andbehaving appropriately.

9.

Information management

The Supplier must comply with any and all applicable data privacy laws and to implement
effective data security, process and handling and other controls in a rigorous manner. This
information management is necessary to prevent any unauthorized disclosure or infringement of
the Supplier’s data.

10.

Product quality and safety

The Supplier shall prioritize the provision of products and services with utmost regard to productsafety. In the event of accidents or defective products, the Supplier shall undertake measures
including disclosure of information, contacting relevant authorities, product recalls, andimplementing safety measures throughout supply chains.

11.

Origin transparency

The Supplier must be able to disclose to Asahi the sources of primary origin (including thecountry of origin) associated with the materials supplied to Asahi.
Asahi may request suppliers of selected materials to map their supply chain back to origin tofacilitate assessment of upstream supply chain compliance.

12.

Grievance mechanism and remediation

The Supplier must have a formal grievance mechanism in place that should be made available
to all workers in its operations (including contractors and workers not covered by a formal
contract of employment). The grievance mechanism must be accessible, easy to understand,legitimate and safe, equitable and rights-compatible, predictable, transparent, confidential, andimprovement-based. The Supplier should outline in its policies that it expects their suppliers tohave an established grievance mechanism in place. In instances where the Supplier’s supplierdoes not have an established grievance mechanism, the Supplier must provide access to its
formal grievance mechanism for its suppliers’ workers and must make them aware how toaccess its grievance mechanism. The grievance mechanism shall define a timebound approach
to investigation and contain clear escalation procedures and provide for remediation. Intimidation
or retaliation against workers utilizing the grievance mechanism is prohibited.
If the Supplier identifies a substantiated grievance within its own operations or supply chain, theSupplier must promptly notify its relevant Asahi contact and the Supplier must cooperate with
Asahi in undertaking remediation activities.

12.1

Prohibition against retaliation

Asahi prohibits Suppliers from retaliating against individuals or groups raising complaints orconcerns about Supplier conduct. Retaliation includes, but is not limited to, physical,
psychological, economic, or legal harm.

13.

Sub-contracting

Asahi seeks to limit sub-contracting of the production of goods and/or services. Where
reasonable, Asahi may require suppliers to obtain prior approval in writing for any subcontracting or prohibit sub-contracting. While Asahi reserves the right to restrict or prohibit subcontracting, such measures will be considered on a case-by-case basis.

Where sub-contracting is occurring subject to agreed-upon terms, the sub-contracted
workplaces are expected to meet the Supplier Code of Conduct expectations. Further, theSupplier is required to make this Supplier Code of Conduct available to its sub-contractors andAsahi expects such sub-contractors to comply with the Supplier Code of Conduct.

14.

Performance monitoring and compliancebreaches

Suppliers must be able to demonstrate compliance with the Supplier Code of Conduct at therequest and to the satisfaction of Asahi.
Asahi may utilize independent auditors to assess Supplier compliance with this Supplier Code of
Conduct. These assessments may include conducting questionnaires, meetings withmanagement, a tour of the facility, confidential interviews with workers on site and a review of
documentation. When contracting with agents or traders, Asahi may also elect to have their
manufacturing or farming Suppliers assessed for compliance.
The Supplier must provide all necessary and requested information for evaluation andassessment of potential modern slavery risks and comply with any request to verify compliancewith this Supplier Code of Conduct with audits at any point during the contractual relationship. If
advised by Asahi, it is recommended the Supplier registers with the Supplier Ethical Data
Exchange (SEDEX), and completes, reviews, and submits any updates to their SEDEX
questionnaire on a regular basis. Asahi may accept other third-party self-assessment
questionnaires (SAQs) and other approved SAQ and audit schemes (refer to the Asahi Group
Responsible Procurement - Supplier Guidelines). Asahi may also request Suppliers to have an
ethical audit performed by an independent approved third party. The Supplier must ensurecompliance with all relevant modern slavery laws in all countries of operation.
Acceptance of this Supplier Code of Conduct, or its own comparable code where that is in place,is a pre-requisite for becoming a supplier to, or renewing a supplier relationship with, any
member of the Asahi Group. Through the signing of our contract terms and/or acceptance of ourpurchase order which cross refers to this code, the Supplier commits that its operations are
subject to the provisions contained in this Supplier Code of Conduct.

All Suppliers and employees will comply with legislation, regulations, and other relevant
obligations that apply to them, in the various capacities in which we operate as individual entities
and as partners.
Should a Supplier at any time become aware that they are unable to comply with the Supplier
Code of Conduct, the Supplier must promptly raise the non-compliance with its relevant Asahi
contact. If you are ever in doubt about your obligations and responsibilities under this Supplier
Code of Conduct, please seek advice from your primary contact at Asahi, or your supervisor.
If Asahi becomes aware that a Supplier is not in compliance with this Supplier Code of Conduct,
Asahi may require corrective measures to be implemented within reasonable timeframes
determined by Asahi (having regard to the nature and circumstances of the non-compliance).
Depending on the nature of the non-compliance, Asahi may support the supplier in addressing
the corrective actions to achieve compliance with this Supplier Code of Conduct.
Non-compliance with this Supplier Code of Conduct may result in termination or suspension of
Asahi’s arrangements with the Supplier.

15.
Owner:

Policy Review

Approver/Issued by:Documentation
Administrator:

Tomas Veit - CEO Asahi Asahi Group
Global Procurement
Holdings Group(AGPRO CEO)
CFO/ AGPRO CEO

Morgan Cleland –Global Sustainability
Lead (Responsible
Procurement)

Effective
from:

AUG-08-24

Revision
No.

Date:

1.

AUG-08-26

Description:

Revised by: