TABLE OF CONTENTSIntroduction3Purpose of Code3Scope4Core Principles1. Responsible Consumption52. Directing Marketing and Advertising to Legal Purchase Age Adults53. Responsibility Message 64. Hazardous and Dangerous Activities65. Performance, Medical and Therapeutic Claims76. Alcohol Content77. Social Content78. Sexual Content79. Consumer Research Policy810. Product Innovation and Presentation911. Promotional Events, Sampling and Sponsorships912. Electronic/Digital/Direct Marketing1013. Product Placement1014. Licensing and POS1115. Compliance Procedures11Contact Information13

INTRODUCTIONBeam Suntory Inc. (“Beam Suntory”) proudly produces and markets some of the world’s finestbeverage alcohol products in many countries around the globe. Production and consumption patternsdiffer widely from one country or region to another and particularly with regard to different categoriesof beverages, all of which have their own individual characteristics and place within respective localcultures. With this in mind, the Beam Suntory Marketing Code of Practice (the “Code”) demonstratesour commitment to the responsible advertising and marketing of our brands.As a global leader in premium spirits, we offer our consumers the keys to responsibility throughdrink smart ( Likewise, all of our Beam Suntory personnel must familiarizethemselves with this Code and the principles of drink smart in order to convey a message ofresponsibility, both in consumption and in our marketing and advertising.Responsible marketing of our products is at the core of our commercial purpose. The Code is aboutconducting our business the right way, the Beam Suntory way. As we grow our business around theworld, we will continue our leadership in responsible consumer communications through the higheststandards of responsible marketing practices.PURPOSE OF CODEThe purpose of this Code is to set the standard for responsible marketing and advertising directed tolegal purchase age (LPA) adults who choose to drink. Our objectives for sales, marketing, promotionand advertising activities are to compete for brand choice among LPA consumers, and to deliverresponsible communications that speak to those consumers.Our commitment to responsibility is demonstrated by upholding the highest standards in brandmarketing and reminding LPA adults who choose to consume beverage alcohol to do so with respectand in moderation.In many countries, there are national or regional advertising and marketing codes, laws andregulations, both mandatory and self-regulatory. This Code is intended to complement these localcodes and requirements while also providing responsible company standards in countries wheremarketing codes and local regulations are not yet in effect.Our Code and the principles it contains also provide guidance to those with whom we do business,to help ensure our brands are marketed and promoted in a responsible manner to LPA adults. Wealso expect and require our partners to employ the high standards we have set for the promotion andsale of our brands.3

SCOPECompliance with this Code is mandatory for all of the Beam Suntory family of companies.This Code applies to all our beverage alcohol products, including those sold on behalf of thirdparties. This Code applies to all brand advertising, consumer communications, trade advertising,promotions (both on- and off-premise), sampling, merchandising, brand websites and directmarketing, point-of-sale materials, brand innovation, consumer planning and research, consumerpublic relations, events, sponsorship activities and product placement.4

CORE PRINCIPLESAdvertising and marketing must: Be directed to LPA adults. Have content which is designed to appeal to LPA adults and is never intended to be directedtowards or primarily appeal to those under LPA. Be placed in media outlets and locations where at least 70% of the audience is reasonablyexpected to be LPA adults. This percentage may be higher in some markets (e.g. United Stateswhere the Media Placement Standard is 75% of LPA, reaching an annual aggregate of 85%of LPA). Be legal, decent and truthful, conforming to the accepted principles of fair competition andgood business practice. Maintain social and ethical standards with respect to gender and cultural differences. Reflect Beam Suntory’s commitment to social responsibility.I. Responsible Consumption:Advertising and marketing must: Present our brands to consumers in a responsible manner. Not encourage excessive or irresponsible consumption or present abstinence or moderation ina negative way. This applies to the amount of beverage alcohol being consumed as well as themanner in which it is portrayed. Never suggest any association of alcohol consumption with violent, daring, dangerous, unruly oranti-social activities. Never suggest any association with illegal drugs or drug culture. Not suggest, condone or promote intoxication or excessive drinking. Not be directed to pregnant women or women trying to become pregnant.2. Directing Marketing and Advertising to LPA Adults:Advertising and marketing must: Be directed and designed to appeal to a LPA adult audience. Not depict children or portray objects and images, such as Santa Claus or cartoon figures, orplaced and/or constructed in a way that primarily appeals to persons below LPA. Not appear in sections of newspapers, magazines or other publications or programming thatmight specifically appeal to those under LPA (e.g. comic pages). Not employ or utilize religion or religious themes. Not associate our brands with the attainment of, or “rite of passage” to, adulthood.5

Employ actors and models in advertisements, promotional materialsor point-of-sale, proven to be at least 25 years of age (and reasonablyappear to be LPA or older), substantiated by proper identification. Not use the term “Spring Break” in promotional related activities ormaterials. This is a term synonymous with spring recess/vacation fromschool for those under LPA in North America.3. Responsibility Message:Advertising and marketing must: Include a responsible drinking message. This message must beplaced horizontally and be clearly legible and noticeable to consumers. Placement and message may vary across marketing materialsand will be determined by the size and material of thecommunication element. Further guidance is provided in the Social ResponsibilityStatement Execution Guidelines document on theBeam Suntory Stir Portal. The only exception is when the item is so small that themessage would be illegible and no other creativealternatives exist for inclusion.4. Hazardous and Dangerous Activities:Advertising and marketing may: Suggest or depict consumption of beverage alcohol as part ofrelaxing or celebration after active recreation or work, as longas the setting and depiction make it reasonably clear that theactivity requiring alertness or coordination has ended. Oneexample would be an “après-ski” celebration in a ski lodge.Advertising and marketing must: Not encourage or condone driving mechanically propelledvehicles or operation of potentially dangerous machinery whileunder the influence of alcohol. Not depict actual consumption of our products. Not depict alcohol beverage consumption with participation inactivities that could be particularly dangerous while consumingalcohol, such as swimming, sailing, bicycle riding, skiing,horseback riding; or the performance of potentially hazardousactivities of any kind which require a high degree of alertness6

5. Performance, Medical and Therapeutic Claims:Advertising and marketing must: Not create the impression that consumption of alcohol enhances mental ability or physicalperformance. Not suggest alcohol has medicinal and therapeutic qualities. Not attribute the ability to prevent, treat or cure a human disease to alcohol or refer to suchproperties.6. Alcohol Content:Advertising and marketing must: Only display truthful information on alcohol strength and not emphasize alcohol strength as apositive attribute of the brand. Not misrepresent the alcohol strength of the brand or its alcohol content. Not imply that consuming brands of low alcohol strength will avoid abuse or intoxication.7. Social Content:Advertising and marketing may: Portray alcohol consumption as part of responsible personal and social experiences.Advertising and marketing must: Not suggest the success of an occasion depends on the presence or consumption of alcohol. Not contain claims that individuals can attain social, professional, educational or athletic successor status as a result of beverage alcohol consumption. Not create the impression that consumption of alcohol will increase confidence, popularity orsocial success.8. Sexual Content:Advertising or marketing may: Portray people in a social or romantic setting showing affection, or who appear to be affluentor attractive.Advertising and marketing must not contain or depict: Alcohol consumption as enhancing sexual attractiveness or as a requirement or enhancementfor sexual success. Graphic or gratuitous nudity, overt sexual activity, promiscuity or sexually lewd or indecentimages or language. Words or imagery that may offend local and generally prevailing standards of taste and decency.7

9. Consumer Research Policy: All consumer research will be conducted only with consumers of LPA. No effort will be made tolearn about consumers’ habits, practices, beliefs or any other points of view about alcohol brandsas they held them prior to reaching LPA. Consumer research from a specific market cannot be utilized in brand planning for markets wherethe LPA is higher than the LPA in the market where the research was conducted, unless allresearch participants are over the LPA in both markets.87

10. Product Innovation and Presentation: Beam Suntorywill not develop or promote its brands as “energy drinks.” Beam Suntorywill not promote its brands with any products marketedas energy drinks.11. Promotional Events, Sampling and Sponsorships:Promotional and sponsorship activities must not encourageirresponsible, excessive or illegal consumption. In line with other elements of this Code, Beam Suntory will ensurethat promotional and sponsorship activity:- Is directed to LPA adults.- Any staff, models or volunteers must be at least LPA.- Maintains social and ethical standards with respect to genderand cultural differences.- Meets all national (and local) legal and regulatoryrequirements, including charitable fundraising laws. Specifically, promotions cannot encourage:- Rapid drinking- Drinking and driving- Binge drinking- Exceeding any recognized governmentconsumption guidelines- Intoxication Branded merchandise will not be offered and must not havea primary appeal to those under LPA. Beam Suntory will only engage in promotions, samplings andsponsorship when at least 70% of the audience in the settingcan be expected to be of LPA. This percentage may be higherin some markets (e.g. United States where the standard is75% of LPA, reaching an annual aggregate of 85% of LPA). When organizing sampling or promotional events, followthese guidelines:- Sampling of beverage alcohol must not be offered to thoseunder LPA.- Prior to undertaking any sampling activity, all necessaryapprovals must be obtained (including any necessary permit,license and/or regulatory approvals).9

- Sampling and promotional events must encourage responsible consumption and behavior, theyshould discourage any activity that would encourage excessive/abusive consumption.- All sampling personnel must be LPA or older, briefed on the Code, and understand local/regional laws and regulations.- Consideration should be given to providing water, or non-alcoholic drinks and light snacks,where allowed. Any sponsorship involvement with activities that might be hazardous after alcohol consumption(e.g. motorsports) must ensure that no link is made suggesting that alcohol consumption isappropriate while undertaking such activities; nor that success in these pursuits is enhanced byalcohol consumption.12. Electronic/Digital/Direct Marketing: The standards of the Code apply to all media platforms, including digital media, which is usedto transmit commercial communications made or generated by Beam Suntory. Guidelines fordigital marketing can be found on the Beam Stir Portal/Digital Marketing Guidelines. The DigitalMarketing Guidelines apply to branded digital marketing properties, including but not limitedto brand websites and brand pages, social network sites and blogs, as well as mobilecommunications and applications. Given the rapidly changing pace of digital media, the policies outlined may not always address aspecific situation. Where our policies do not cover a specific circumstance, clearance processmust be followed through Marketing, Legal and/or Industry Affairs.13. Product Placement:Product placement in movies, television or music video productions will be considered if: The production is directed and primarily appeals to an adult audience. Content does not feature underage drinking, excessive drinking or other irresponsibleconsumption such as driving while intoxicated. Content does not feature violence or aggression linked to alcohol consumption. Primary characters are of LPA. Exceptions may be made on a case-by-case review and assessment of overall thematic content.10

Product placement will only be approved if: Sufficient information is provided to prove the specific scene and setting in which the brand(s)will be featured and the overall context in which the brand and the character(s) consumingbeverage alcohol in the production are compliant with the social responsibility guidelines outlinedin this Code. Written consent is provided to producers and film companies to use our brands. If a script isdeemed inappropriate, written communication must be sent to the relevant party denyingpermission to use the brands.14. Licensing and POS:The following are examples of items which are inappropriate for point-of-sale,merchandising or licensing: Materials primarily appeal to persons under LPA. Candy, except for gourmet chocolates or other high-end confectionery items which are clearlyintended for adults. Sexual paraphernalia, e.g., condoms. Drug-related paraphernalia. Guns, knives or items generally referred to as weapons, except tools or cutlery items for culinarypurposes and adult sporting activities.15. Compliance Procedures: All Beam Suntory personnel must be familiar with this Code and comply with all its provisions. Advertising agencies, market research companies, media buyers and other third parties involvedwith the marketing and advertising of our brands must receive a copy of this Code and mustabide by its provisions in any work they do on behalf of Beam Suntory and its brands. All Beam Suntory personnel responsible for marketing and promotional materials and activitiesmust complete compliance training and are required to adhere to this Code and take part inperiodic training. All regional businesses must establish and adhere to processes to ensure compliance to theletter and the spirit of this Code, local laws and regulations, consumer promotions and privacylaws, intellectual property laws and best practices, and applicable national and regionaladvertising marketing codes. Code compliance is the fundamental responsibility of our in-market business general managers,and covers all marketing, advertising and promotional materials and activities in the on- andoff-trade and is required for brand innovation activities, brand launch campaigns, consumer publicrelations and all other brand communication activities.11

Complaint procedures for alleged non-compliance with the Code are included on thecorporate website ( to allow interested parties to register potentialgrievances confidentially. Beam Suntory will evaluate alleged grievances regarding Code compliance registeredwith the company and record and respond to the parties registering such grievances, asdeemed appropriate.12

CONTACT INFORMATIONFor further information on the Beam Suntory Marketing Code of Practice, or corporate socialresponsibility issues, please contact: [email protected]

Beam Suntory Stir Portal. The only exception is when the item is so small that the message would be illegible and no other creative alternatives exist for inclusion. 4. Hazardous and Dangerous Activities: Advertising and marketing may: Sug