Asahi Group
Responsible
Procurement Policy

Table of Contents
1.

Introduction .................................................................................................................... 4

2.

Statement of intent ......................................................................................................... 4

3.

Scope and applicability .................................................................................................. 5

4.

Our expectations ............................................................................................................ 55.

Responsible Procurement Program ............................................................................... 6

6.

Grievance handling and remediation mechanisms ......................................................... 8

7.

Related Asahi Responsible Procurement frameworks, policies, and guidance material . 9

8.

Glossary of terms ........................................................................................................... 99.

Policy review ................................................................................................................ 11

Asahi Group Responsible Procurement Policy2Issuing Function /Author
CEO Asahi Global Procurement
Target audience
This Group Responsible Procurement Policy 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.
Approver
Asahi Group Holdings, Ltd. Group CFO
Date of publication
August 08/2024
Order of precedenceThis Group Responsible Procurement Policy takes precedence at any time over any local orregional policy, and in case of any differences between any Asahi regional entity and local entity
Procurement policies, the Asahi Group Responsible Procurement Policy shall take precedence.
Disclaimer
This Asahi Group Responsible Procurement Policy 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 Responsible
Procurement Policy alongside local laws and regulations. In case of conflict, local laws takeprecedence. This Responsible Procurement Policy is reviewed periodically and may be
updated.

Asahi Group Responsible Procurement Policy

3

1. Introduction
At the Asahi Group (also ‘Asahi’, ‘we’, ‘our’), we source products and services from across theworld. Due to the nature and scale of our business, we have significant potential to drive positivesocial and environmental outcomes through our procurement activity. We expect strong social andenvironmental standards from our suppliers and aim to support our suppliers to implement moresustainable practices.
The Asahi Group Responsible Procurement Policy (the ‘Policy’) outlines our expectations of all our
suppliers. Our expectations are guided by our commitment and approach to implementing andmaintaining responsible procurement practices that protect the human rights of workers andcommunities in our supply chains and safeguard the natural world.
This Policy should be read alongside our Asahi Group Human Rights Principles and our Asahi
Group Environmental Principles. Our Asahi Group Human Rights Principles set out ourcommitment to respecting human rights in our own operations and supply chain.
This Policy, alongside the Asahi Group Supplier Code of Conduct (the ‘Supplier Code of Conduct’)and the Asahi Group Responsible Procurement - Supplier Guidelines (the ‘Guidelines’) sets out
the requirements of our suppliers as part of our broader Responsible Procurement Program (the‘Program’).

2. Statement of intent
Statement

We strive to responsibly source our products and services to deliver on our
vision to create inspiring and empowering supply chains that protect thehuman rights of workers and communities and safeguard nature. Essential
to achieving this is partnering with our suppliers who share our commitment
and agree to abide by the requirements set out in the Policy, and who
encourage their own suppliers to embed the requirements throughout thevalue chain.

Values-driven
sourcing

Ensuring that our suppliers embrace similar values-driven sourcing
practices is essential to realizing our vision. We strive to invest sufficient
resources in order to fulfil our responsible procurement commitments.

Responsible
purchasing
practices

We recognize that our purchasing practices may have significant potential
to enable or impede our suppliers’ ability to meet the expectations of thisPolicy. Asahi strives to use responsible purchasing practices to support our
suppliers, including:►►►►

Capacity building

Agreed-upon order quantities;
Fair payment terms;
Fair purchasing terms and conditions; andLead time and technical details for suppliers to create or deliver
our purchased product or service.

We acknowledge that the adoption of values-driven sourcing andresponsible purchasing practices will require increased capacity andexpertise for our suppliers. We have the capabilities to provide appropriate
guidance, tools and training to assist our suppliers in adopting and abiding
by the requirements set out in the Policy, as feasible and within our
resources.

Asahi Group Responsible Procurement Policy

43. Scope and applicability
Scope andapplicability of the
PolicyThe Policy applies to all Asahi suppliers, specifically:► All suppliers of the Asahi Group; and► All direct and indirect suppliers across all commodity categories.
All suppliers are expected to abide by and adhere to the expectations set
out in the Policy at all times whilst supplying goods and/or services to Asahi
or its subsidiaries. The Policy defines minimum expectations but does notprevent our suppliers from exceeding these expectations.

4. Our expectations
Summary of
expectations

The Policy, together with our Supplier Code of Conduct and Guidelines setsout our expectations of our suppliers in areas of business integrity, humanrights and labor standards, nature, and grievance mechanisms.
As a condition of doing business with Asahi, suppliers must be able toprovide evidence that they meet our expectations contained in the Supplier
Code of Conduct, including policies, management systems, procedures
and resourcing appropriate to their capacity and risk level.

Alignment of the
Supplier Code of
Conduct tointernationalframeworks

The Supplier Code of Conduct reflects Asahi’s commitment and alignment
to internationally recognized frameworks, guidelines, and standards,
including:Nonconformances andresponse

We expect our suppliers to be honest and transparent in their dealings with
us and to commit to making continual improvements in their operations andsupply chains.

► 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 theInternational Covenant on Civil and Political Rights (ICCPR);► The United Nations (UN) Guiding Principles on Business andHuman Rights;► The International Labor Organization (ILO) Declaration on
Fundamental Principles and Rights 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;► The International Convention on the Protection of All MigrantWorkers and Members of Their Families;► 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 and Social Policy.

Asahi Group Responsible Procurement Policy

5Where Asahi determines a supplier is not in conformance with any
requirements of the Program, we will work with the supplier to ensure theissue is appropriately remediated for affected parties. We will work
collaboratively with the supplier to develop and implement a SupplierManagement Plan (SMP) to close out any identified Non-Conformances(NCs) which will then be monitored by Asahi as part of the Program’s
ongoing verification and monitoring activities.
Suppliers must demonstrate genuine progress in the implementation of the
SMP in accordance with the required timeframes. Following internal
processes for the responsible exit of a supplier relationship, Asahi reserves
the right to discontinue our relationship with the supplier. This may occur inthe rare instance that the supplier is both unwilling and unable to close out
their SMP within the specified timeframes.

5. Responsible Procurement Program
About theProgramOur Responsible Procurement Program outlines Asahi’s process formonitoring and managing supplier performance and verifying suppliercompliance with the requirements of the Supplier Code of Conduct, Policy
and supporting Guidelines. This approach is also designed to support
continuous improvement processes through SMPs and broader
stakeholder feedback into the Program.
The Program adopts a risk-based approach and focuses on suppliers witha higher risk of NC with any requirements of the Program, and with whom
we have greater leverage to influence performance improvement.

Activemanagement
suppliers

Suppliers are subject to active management based on an assigned risk
level, which is determined through various stages of the Program. Supplierrisk is regularly re-assessed.
Suppliers are notified whether they are subject to active management via
our supplier management system.
Details of Program requirements for all prospective suppliers and active
management suppliers are outlined in the following sections.
For additional information and guidance on our Program, please refer to the
Guidelines. Please reach out to your Asahi contact or purchasing contact,
if you have any questions on the Program.

Ongoing suppliermonitoring andverification ofcompliance

Supply chain traceability and transparency are critical to enableimprovements with our suppliers. We use a range of due diligence tools via
the Program to monitor compliance with the Supplier Code of Conduct,
including the following:
All prospective suppliers will:► Accept the Policy and the Supplier Code of Conduct by attestation
during supplier registration on our supplier management system;► Receive a copy of the Guidelines during supplier registration: and► Participate in training and development programs (as required).
Active management suppliers will also:► Complete a pre-screening questionnaire based on the assigned
risk level;

Asahi Group Responsible Procurement Policy

6► Provide details of any third-party product certifications (where
relevant);► Complete a Self-Assessment Questionnaires (SAQ) whenrequested by Asahi;► Undertake a third-party audit, where requested by Asahi;► Develop and implement an SMP depending on the outcome of the
SAQ or third-party audit; and► Allow an Asahi site visit when requested by Asahi.
Asahi reserves the right to require a third-party audit or conduct a site
visit of any supplier at its discretion. Asahi also reserves the right torecognize certain third-party product certification schemes in lieu of
third-party audits (see section Third-party product certification
schemes).
Third-party
product
certification
schemesAsahi views third-party product certification schemes as a risk
management tool to supplement our own due diligence processes,
especially for products with the potential for high social and environmental
impact.
Asahi places priority on procuring third-party certified products for thefollowing categories and recognizes the verification processes under theseschemes in lieu of our third-party audit requirements.
Paper products for packaging and office use
Paper certified by the Forest Stewardship Council (FSC) or Program for
the Endorsement of Forest Certification (PEFC).
CoffeeCoffee product suppliers who are able to provide evidence of coffee
production that generates positive and mitigates negative social andenvironmental outcomes from farm to Asahi. Asahi may accept Fairtradeor Rainforest Alliance certified products.
Palm OilRoundtable on Sustainable Palm Oil (RSPO) independently certified
palm oil products, derivatives, and fractions.
Tea
Fairtrade and Rainforest Alliance independently certified tea products.
Cocoa
Fairtrade and Rainforest Alliance independently certified cocoa products.
Sugarcane
Bonsucro and Fairtrade independently certified sugarcane products.
Barley/Malt
Recognized farm-level assessments include SAI Platform’s Farm
Sustainability Assessment (FSA) Gold and Silver performance level sites
under the FSA self-assessed strategy.
Asahi may accept alternative certification schemes at its discretion.

Driving
improvements forworkers andWe recognize the challenges of local contexts and that many social andenvironmental issues can take time and effort to resolve. As a minimum, we
require our suppliers to commit to implementing our Supplier Code of

Asahi Group Responsible Procurement Policy

7communities

Conduct and the local law – whichever provision affords the greater
protection to workers.
We will work collaboratively with our suppliers who demonstrate acommitment to continuous improvement in their performance and address
and remediate issues when they arise to deliver positive outcomes for our
suppliers, their workers and broader communities in which they operate.
In the longer-term, we will work with suppliers and workers to develop bestpractice on responsible procurement and positive examples which secure
workers’ rights alongside benefiting our suppliers’ businesses and our own.

Building
partnerships with
our suppliers andthe industry to
advocate forchangeSystemic issues such as forced labor and discrimination can only be
addressed through multi-stakeholder collaborations. We aim to collaborate
with our suppliers, non-governmental organizations, third-party productcertification schemes, membership organizations, governments, otherconsumer goods manufacturers and the wider industry to find andimplement solutions.
As part of the process of evaluating the Program, Asahi will engage withaffected stakeholders including suppliers, certification schemes, multistakeholder membership organizations and NGOs as required.

6. Grievance handling and remediation mechanisms
We aim to prevent any human rights infringement, whether caused directly by our operations, orindirectly through the actions of our suppliers. If we identify that we have caused or contributed tosuch infringement, we will take appropriate corrective actions to remediate harm in cooperation
with our suppliers.
Grievance
Mechanism

As required in the Supplier Code of Conduct, we expect our suppliers tohave a formal grievance mechanism in place that should be madeavailable 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 and improvement-based.
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 madeto Asahi’s Speak Up channel. This channel is independently operated by
an external party and is available 24/7, 365 days a year, in various local
languages of the countries/regions which we operate in. The Speak Upchannel can be used anonymously and is intended to be confidential. Users
may access the Speak Up channel 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.

Asahi Group Responsible Procurement Policy8Remediation

Where a substantiated adverse impact is identified, we expect our suppliers
to provide remediation to all impacted workers in their operations andsupply chains. Adverse impacts may be substantiated by evidence that is
identified and verified by investigation through avenues such as, but notlimited to, Asahi or the supplier’s grievance mechanism.

7. Related Asahi Responsible Procurement frameworks,
policies, and guidance material►►►►

Asahi Group Global Supplier Code of Conduct
Asahi Group Responsible Procurement - Supplier Guidelines
Asahi Speak Up Policy
Asahi Group Human Rights Principles

8. Glossary of terms
Active management(suppliers)

Within scope of the Program’s due diligence activities.

Activities conducted to exercise reasonable care, investigate, verify
and assess all potential risks of adverse impacts associated with abusiness’ supply chain or a specific business transaction or decision.
Due diligenceDue diligence may involve examination of financial records, legal
documents, operational mechanisms, and other relevant factors. For
human rights this could involve suppliers answering SAQs to identify
risks. The standard and scope of due diligence may vary based on abusiness’s size and nature of the business agreement.

Grievancemechanism

Any routinized process through which grievances concerning businessrelated negative impacts can be raised and remedy can be sought 1.

Non-conformance(NC)

An instance where the supplier’s practices do not meet any
requirements of the Program.

Prospective supplierSuppliers who have expressed interest in becoming an Asahi supplierbut have yet to participate in the Program.

Remediation

The process of providing remedy for an adverse impact and thesubstantive outcomes that can counteract, or make good, the adverse
impact. These outcomes may take a range of forms such as apologies,
restitution, rehabilitation, financial or non-financial compensation, andpunitive sanctions (whether criminal or administrative, such as fines) as
well as the prevention of harm through, for example, injunctions orguarantees of non-repetition2.

Self-Assessment
Questionnaire (SAQ)

A series of questions to be completed by active management suppliers
that assesses the existence of risk management controls.

Asahi Group Responsible Procurement Policy

9Site visit

An in-person activity conducted by Asahi to verify, be examination andevaluation of objective evidence, that applicable elements of a supplier’s
management systems are approved, effective and conform with therequirements of the Program.

Supplier Management
Plan (SMP)

A set of specific, timebound actions for suppliers to implement to raise
their performance relating to the requirements of the Program. The SMP
will be developed by Asahi in consultation with the supplier and isinformed by a combination of inputs such as, but not limited to, the prescreening questionnaire, self-assessment questionnaire, third-party
audits and Asahi site visits.

Third-party audit

A means of evaluating sufficient evidential matter to assess
performance relative to a set of standards set by a third-party program3.
A procedure by which a third-party scheme:•

Third-party productcertification•

Establishes standards or similar tools focused on one or moresustainability issues;
Measures, monitors, or verifies performance or progress against
these tools; andAllows for claims to be made by the organization with reference to thesetools4.
Forest StewardshipCouncil (FSC)

FSC forest management certification confirms that the forest is being
managed in a way that preserves biological diversity and benefits the
lives of local people and workers, while ensuring it sustains economic
viability5.

Program for theEndorsement ofForest Certification(PEFC)

PEFC, the Program for the Endorsement of Forest Certification, is aleading global alliance of national forest certification systems. As aninternational non-profit, non-governmental organization, we arededicated to promoting sustainable forest management throughindependent third-party certification6.

Fairtrade

Fairtrade supports and challenges businesses and governments andconnects farmers and workers with the people who buy their products7.

Rainforest Alliance

The Rainforest Alliance is an international non-profit organizationbuilding an alliance to protect forests, improve the livelihoods of farmers
and forest communities, promote their human rights, and help themmitigate and adapt to the climate crisis8.

Roundtable on
Sustainable Palm Oil(RSPO)RSPO Certification assures individuals that RSPO Members who
produce or physically handle RSPO Certified Sustainable Palm Oil(CSPO) have obtained RSPO Certification. It includes the assurance
that the member has committed to and complied with sustainability
requirements, and can make a claim on their certification status andcommunicate this throughout the supply chain9.

Bonsucro

Bonsucro offers a credible, metric certification process to demonstratecommitment to environmental and social sustainability in sugarcane 10.

SAI Platform’s Farm
Sustainability

The Farm Sustainability Assessment (FSA) enables food and drink
businesses to assess, improve, and validate on-farm sustainability inAsahi Group Responsible Procurement Policy

10Assessment (FSA)

their supply chains. Built around a simple set of questions to farmers,
the FSA standardizes farm assessment11.

9. Policy review
Owner:

Approver/Issued by:Documentation
Administrator:

Tomas Veit - CEO
Asahi Global
Procurement

Morgan Cleland –Global Sustainability
Lead (Responsible
Procurement)

Kaoru Sakita Group CFO Asahi
Group Holdings

Effective
from:

AUG-08-2024

Revision
No.

Date:

1.

AUG-08-2026

Asahi Group Responsible Procurement Policy

Description:

Revised by:11