INTRODUCTION

Beam Inc. ("Beam") proudly produces and markets some of the world's finest beverage alcohol products in many countries around the globe. Production and consumption patterns differ widely from one country or region to another and particularly with regard to different categories of beverages, all of which have their own individual characteristics and place within respective local cultures. With this in mind, the Beam Marketing Code of Practice (the "Code") demonstrates our 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 through drink smart® (www.drinksmart.com). Likewise, all of our Beam personnel must familiarize themselves with this Code and the principles of drink smart® in order to convey a message of responsibility, 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 about conducting our business the right way, the Beam way. As we grow our business around the world, we will continue our leadership in responsible consumer communications through the highest standards of responsible marketing practices.

PURPOSE OF CODE

The purpose of this Code is to set the standard for responsible marketing and advertising directed to legal purchase age (LPA) adults who choose to drink. Our objectives for sales, marketing, promotion and advertising activities are to compete for brand choice among LPA consumers, and to deliver responsible communications that speak to those consumers. Our commitment to responsibility is demonstrated by upholding the highest standards in brand marketing and reminding LPA adults who choose to consume beverage alcohol to do so with respect and in moderation. In many countries, there are national or regional advertising and marketing codes, laws and regulations, both mandatory and self-regulatory. This Code is intended to complement these local codes and requirements while also providing responsible company standards in countries where marketing 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. We also expect and require our partners to employ the high standards we have set for the promotion and sale of our brands.

SCOPE

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

CORE PRINCIPLES

Advertising and marketing must:

1. Responsible Consumption:

Advertising and marketing must:

2. Directing Marketing and Advertising to LPA Adults:

Advertising and marketing must:

3. Responsibility Message:

Advertising and marketing must:

4. Hazardous and Dangerous Activities:

Advertising and marketing may:

Advertising and marketing must:

5. Performance, Medical and Therapeutic Claims:

Advertising and marketing must:

6. Alcohol Content:

Advertising and marketing must:

7. Social Content:

Advertising and marketing may:

Advertising and marketing must:

8. Sexual Content:

Advertising or marketing may:

Advertising and marketing must not contain or depict:

9. Consumer Research Policy:

10. Product Innovation and Presentation:

11. Promotional Events, Sampling and Sponsorships:

Promotional and sponsorship activities must not encourage irresponsible, excessive or illegal consumption.

12. Electronic/Digital/Direct Marketing:

13. Product Placement:

Product placement in movies, television or music video productions will be considered if:

Product placement will only be approved if:

14. Licensing and POS:

The following are examples of items which are inappropriate for point-of-sale, merchandising or licensing:

15. Compliance Procedures:

CONTACT INFORMATION

For further information on the Beam Inc. Marketing Code of Practice, or other compliance issues, please contact the local in-market general manager or:

Allyson Wilcox
Assistant General Counsel
Beam Inc.
510 Lake Cook Road
Deerfield, IL 60015
(847) 444-7111 (phone)
allyson.wilcox@beamglobal.com

Pino Bermudez
Assistant General Counsel
Beam Global España
c/Arturo Soria n 107, 28043
Madrid, Spain
011 34 91 353 46 31 (phone)
pino.bermudez@beamglobal.com

Paula Valdes
Legal Counsel Beam Inc.
Av. Vallarta no. 6503
Local 49E
CP 45010 Zapopan, Jalisco
Mexico
52 33 3679 06 00 (phone)
paula.valdes@beamglobal.com

For general marketing inquiries, please contact the Marketing Department.