CONTENTS

INTRODUCTION BY FACUNDO L. BACARDI & MAHESH MADHAVAN

WHY A CODE OF CONDUCT?

Raising questions or concerns about the Code

OUR INTEGRITY AND RESPONSIBILITIES

Equal opportunities

Respect for each other

Conflict of interest

Gifts, hospitality & entertainment

Company physical property & I.T. Resources

Company records, financial reporting & auditors

Intellectual property

Protecting business information

Protecting personal information

Social media personal use

Corporate responsibility (charitable contributions & sponsorships)

COMPLIANCE

Compliance with laws, rules and regulations

COMMERCIAL PRACTICES

Fair competition

Distribution practice

Environment health & safety

Economic sanctions

Insider trading and securities law compliance

Anti-bribery and corruption

Social responsibility in marketing practices

Illegal trade

Relationships with suppliers and business partners

Political activities & contributions

OUR INTERACTION WITH GOVERNMENTS & MEDIA

Government inquiries and investigations

Media relations

WE ARE HERE TO HELP!

INTRODUCTION

BY FACUNDO L. Bacardi, Chairman AND Mahesh Madhavan, CEO

We often reflect on our 150 years history as a family Company and the solid success we have built over generations. In doing so, we must also recognize that the trust of our consumers, employees, business partners and communities provide key pillars for our success. We reinforce that trust constantly as everyone Bacardi engages comes to appreciate the quality of our products and our people, including our commitment to ethical conduct. Trust is one of our most valuable assets and it’s one of the most fragile in today’s world.

As the pace of business accelerates and information of every sort travels the world instantly, we must protect our reputation every day. A careless or short-sighted action can easily start a process where the trust of generations can be tarnished or lost. That is why, the way we conduct our business is as important as the liquids we produce, the brands we market and the Primos we employ.

Abiding by our Values is critical for today and for future generations of our Company.Our Code of Conduct serves as a set of guiding principles to help you make the right decisions and maintain the trust of all our stakeholders.It is not possible for our Code of Conduct to address every situation that you may face.However, if you apply its principles using your good judgment, your experience and you act like a Founder of our Company, your business decisions will demonstrate that we consistently aim to do what is right.

Read our Code and use it to guide your actions. Seek guidance if you are unsure. Strive to do what is right and remain true to Don Facundo’s family legacy.

If you see unethical behavior or have a concern, be Fearless: “Speak up”.

We are proud of all that we have accomplished together and humbled to be part of this great family history. Now it is our responsibility to ensure trust and success for the future, making those years the best!

Facundo L. Bacardi
Chairman of the Board

Mahesh Madhavan
Chief Executive Officer

WHY A CODE OF CONDUCT?

This Code of Conduct describes the most important principles we must uphold in the conduct of our business to affirm our values and protect our future.By upholding these principles, we strengthen the trust we need to succeed all over the world.

While we do recognize that business practices and cultural differences vary from country to country, we also believe that there are general standards we can apply throughout our diverse local environments.

This Code applies to all employees, our business partners and their employees engaged with Bacardi business.

“What are my duties with respect to this code?”

  • Understand the Code
  • Agree to follow it 
  • Reporting of a known or suspected violation.

Remember, speaking up is the Right Thing to Do.Why?Because silence means there is no opportunity for the Company to correct bad behavior; and setting the wrong message leads to more inacceptable behavior. If in doubt, don’t assume. Report!

Raising Questions or Concerns about the Code

We know that you will be faced with situations that raise questions about the best way to conduct our business consistent with our values and principles.

If you have a concern about the application of the Code, please talk to your line manager, an HR representative or a representative of the Legal/Compliance function.

If you do not feel comfortable identifying yourself, please use our external anonymous hotline. By raising a concern in good faith, you help maintain the Company’s high standard of ethical conduct and you help protect the Company.

“CAN I RAISE A CONCERN ANONYMOUSLY?”

Yes, irrespective if you are a Bacardi employee, third party or contractor.

Reporting a concern anonymously (or by identifying yourself) can be done by calling our confidential toll-free hotline or filing a web report. Details for both can be found at
www.bacardiwhistleblowerhotline.com

The Bacardi Hotline service is provided and administered by a well-known and independent 3rd party service provider.

OUR INTEGRITY AND RESPONSIBILITIES

EQUAL OPPORTUNITIES

Bacardi employees are located all over the world and bring to the Company a diverse set of ideas, talent and abilities. Our Company actively promotes a working environment where all employees are treated and rewarded fairly. We do not tolerate any form of discrimination that adversely affects individuals or groups on the basis of national origin, race, color, religion, sex, sexual orientation, marital status, disability, age and other protected characteristic under applicable laws.

This principle of equality and fairness applies to all terms and conditions of employment, including but not limited to recruitment, promotion and termination; compensation and benefits; succession; performance; appraisals and rewards; investigation and penalties.

RESPECT FOR EACH OTHER

Bacardi has a zero-tolerance policy towards sexual harassment and any other form of harassment within Bacardi or at any Bacardi sponsored events.

All employees have the right to work in an environment of trust and respect, that is free from any form of harassment, demeaning actions and bullying of any sort. This zero-tolerance policy extends to any individual contracted through third parties who work for us or provide specific services for our Company (for example, at promotional events).

HARRASSMENT OF ANY TYPE IS UNACCEPTABLE EXAMPLES MAY INCLUDE:

Sexually suggestive remarks, requests for sexual favors, unwelcome physical contact, displaying suggestive or offensive objects or pictures, harassing telephone calls, emails, text or other communications.

Requesting sexual favors as a condition for promotion or recruitment.

Repeated aggressive, intimidating or threatening communication, whether verbal or in writing. Sending or forwarding content through e-mails /online publications/ twitter or other social media, that is – or contain files that are – obscene, illegal or offensive.

Behavior which is intended to or has the effect of marginalizing individuals or groups.

Humiliate an employee publicly.

For more information and guidance on how to prevent and report unacceptable behaviors, please consult the “Integrity First” section.

CONFLICT OF INTEREST

A conflict of interestmay be perceived to exist when there is the potential for an individual’s business decisions to be influenced by personal interests and relationships, whether financial, social, political or family related.

To avoid actual and potential conflicts, it is important that you notify your line manager and your HR representative in writing if a transaction or situation raises any doubts in your mind. When declaring a potential conflict in advance, it may be possible to manage the conflict and seek appropriate corrective actions and approvals.

EXAMPLES OF SITUATIONS THAT MUST BE DECLARED:

  • A Sales Manager covers an area where his/her spouse manages a restaurant, and that restaurant is one of our clients
  • An employee who approves purchase orders for local contracts has a personal relationship with a senior employee of a third-party supplier of Bacardi.
  • A relative is a Sales Director for a large retail chain that is also a customer of Bacardi.
  • Your husband is a Director of a Company developing a low-proof vodka.
  • A Bacardi Director is the Treasurer for a worldwide charity to which Bacardi makes an annual corporate donation.
  • You have shares in a Bacardi competitor, contractor, customer or supplier.
  • Accepting loans or investment opportunities from any Bacardi supplier of goods and services or any actual or potential customer of Bacardi, unless any such loans are on prevailing terms from a recognized financial institution

If you are affiliated with any Bacardi related business either through family, friends or intimate relationships, then it is your responsibility to disclose this in writing to your manager, or HR representative, as soon as you become aware of the potential conflict

GIFTS HOSPITALITY & ENTERTAINMENT

Gifts, hospitality and entertainment (GHE) are part of normal business life.They are an acceptable way of helping to build healthy relationships and goodwill with our business partners and to showcase our brands, provided that some basic rules are followed. In particular, GHE must not be given or received in order to obtain or reward preferential treatment without business justification, as they could be viewed as a conflict of interest. In some jurisdictions, such exchange may even be viewed as an act of bribery.

When exchanging gifts and entertainment, always follow these rules:

  • Become familiar with your local anti-corruption laws, our Travel and Entertainment policy and our Anti bribery and Corruption policy.
  • Do not accept or offer gifts in cash – or that include cash. Gift certificate vouchers are equivalent to cash and should not be given or received, unless under a Company sanctioned program and process. Any cash gift received should be returned or, if a return is culturally not acceptable, handed over to your HR representative, or your local Legal Counsel.
  • Obtain prior written approval for any gift for public officials, from your immediate manager and your Legal Counsel irrespective of the value and occurrence. Such approval should be recorded locally.
  • You are allowed to accept or offer non-cash gifts only if they are in accordance with usual business practices and their value does not exceed the amount of 250 USD (market price of the gift), per business partner and fiscal year. IMPORTANT: Some markets may have more restrictive policies in place; so always ensure your local policy on gifts and entertainment is not more restrictive and imposes lower limits.
  • Entertainment for non-public officials, including brand promotions activities, sales/industry events or visits to our brand homes, is acceptable when occasional, reasonable, in line with local costs and customs, and our policies. Any such entertainment for public officials must be approved by the Global Compliance Officer or the General Counsel.

WHEN SHOULD YOU SEEK ADVICE AND APPROVAL?

Examples:

  • Inviting a business partner for a full day Golf Outing, including lunch and drinks.
  • Accepting an invitation from one of your suppliers to an “all-expense paid” 2-day seminar in a 5-star hotel.
  • Paying for the trip and all related expenses of a public official, to one of the Bacardi plants or any other location abroad
  • Accepting lunch or dinner, or a gift, irrespective of its value, during the course of a tender process

COMPANY PHYSICAL PROPERTY AND I.T. RESOURCES

Our Company’s physical property is to be used for business purposes and it includes our cash, inventory, buildings, I.T. resources, equipment, information, documents, records and the work of our employees.

Information Technology and infrastructure are critical to the success of our operations and must be used responsibly. While moderate personal use of specific information technology (phone, emails) is allowed to accommodate employee needs and travel requirements, you should otherwise only use company property and information technology for legitimate business purposes. Inappropriate use of information technology can lead to unauthorized access to our network and data, theft of business information, damage to software systems and the leakage of confidential information.

DID YOU KNOW?

Inappropriate use of our I.T. network can lead to unauthorized access to Bacardi networks and data, theft of business information, loss of employees and third parties’ personal data, damage to software systems and leakage of confidential information.

COMPANY RECORDS, FINANCIAL REPORTING AND AUDITORS

The integrity of the Company’s record keeping, and reporting systems must be maintained at all times. They must be accurate, complete andtimely to ensure they reasonably and fairly reflect the Bacardi businesses, assets and liabilities, in compliance with applicable laws, rules and regulations, including generally accepted accounting principles and the guidelines of the Company auditors.

Employees are forbidden to make or authorize any misleading entries or off-the-books payments, receipts or accounts that could distort the records or reports of the Company’s operating results or financial condition. This includes any attempts at circumventing review and approval procedures.

The Company’s assets are protected via the Compensation Integrity and Recovery policy. This policy may be enforced in situations where employees have placed the Company’s integrity at risk and their behavior has been found to be inconsistent with the principles of the Code or, where there has been misjudgement of the Company’s financial results thereby producing a miscalculated reward.

WHAT IS “PROCURE TO PAY”?

It describes a system that connects all of the steps of a procurement process, from the decision to buy something to the eventual delivery and payment. Compliance with the “Procure to Pay” Process is critical to protect Company funds and assets. Always make sure that when a vendor bills us, that we have and record the appropriate level of documentation.

INTELLECTUAL PROPERTY

Intellectual property (IP) is vital for ensuring the Company’s growth and profitability and constitutes one of the most valuable assets of Bacardi.

All inventions, ideas and concepts developed by Bacardi and its employees belong to Bacardi and must not be privately used or shared.If your role involves marketing, sales, brand development, product development or innovation activities, you should familiarize yourself with the Company’s policies related to IP and follow the relevant trainings. You should never authorize the use of any intellectual property asset owned by Bacardi without prior written approval from Bacardi Legal Counsel.Similarly, you should not disclose IP innovation projects without the protection of non-disclosure agreements approved by Bacardi Legal Counsel.

You should always respect others’ intellectual property as we do our own.

REMEMBER….

Make sure to use the ® sign behind our own trademarks on pack, advertising, releases, but also behind a third-party trademark when referring to it in our own materials.

Be aware that not respecting third party’s IP rights (for example not conducting proper due diligence and clearance all aspects of our own innovations) could, in the worst case, require a product recall and subject the Company to fines and penalties.

PROTECTING BUSINESS INFORMATION

All business-related information is confidential and only intended for internal use, unless Bacardi has officially and publicly disclosed it. Public disclosures will be officially made by Bacardi following defined processes and time tables to ensure shareholders and bondholders are the first to receive material information.

IN CONNECTION WITH CONFIDENTIAL INFORMATION, YOU MUST:

  • Disclose the information only to authorized persons within Bacardi, who have a need to have the information.
  • Use the information only for the benefit of Bacardi.
  • Obtain prior written authorization from management or Bacardi Legal counsel for the disclosure of any such information to third parties.
  • Understand that your obligation not to disclose confidential information is applicable even after your employment with Bacardi ends.

PROTECTING PERSONAL INFORMATION

We ensure that personal information is handled in accordance with data protection laws. Before engaging in any activity that makes use of personal information, whether this information is related to employees or third parties, you should:

  • Consider data privacy implications.
  • When required by law, ensure that individuals who provide personal information give their consent and are aware of who will have access to that data and for what purpose.
  • Protect personal data from unauthorized access and use.

DID THIS HAPPEN TO YOU?

Most losses related to proprietary company information occur via email errors -by sending for example an email to the wrong recipients.File transfers, chat tools, blog posts, Twitter messages and even online resumes need to be used carefully.

If this happens to you, report it immediately to your line manager, Legal counsel and the IT security team.

Some important tips:

  • Keep computer, mobile phones and portable devices secure with access codes set up on them.
  • Exercise caution when discussing your Company’s business or using your phone or computer in public places, especially on public transportation.
  • Lock your screen when away from your computer and keep your passwords secret and secure.
  • Avoid transferring documents by USB memory devices if at all possible.If you have to use one, carefully monitor location and contents and erase when finished.

Company data should never be stored on third party storage apps like Dropbox.

Cybersecurity:

When company data is compromised, the Company may face significant costs, financial losses, reputational damages and even monetary penalties.

At Bacardi we take the security of our data very seriously and have implemented cybersecurity technologies to protect our business.

However, cybersecurity starts with each one of us: ensure that Bacardi devices are always password protected and do not share your passwords with anyone; be careful when opening emails or links from unknown email senders; do not download or stream unauthorized video or audio files on Bacardi devices and do not install or download
non-approved software on Bacardi devices.

WHAT IS “PERSONAL DATA” AND WHAT DOES “PROCESSING” MEAN?

Personal data includes all data that could be used to identify an individual, such as: name, surname, date of birth, phone number, photographic ID, address, bank account details, email address etc.

“Processing” covers almost everything related to the handling of data, such as:Collection, Recording, Organization, Structuring, Storing, etc., Organizing data, or sharing it for review by email are examples of processing.

Note that paper files are also included in the definition of “processing data”.

SOCIAL MEDIA PERSONAL USE

As we embrace the Founders Mentality, we have the opportunity to celebrate Bacardi culture every day and recognize that social media constitutes a great opportunity to communicate about our brands and Company. However, as the popularity of social media grows, the far-reaching communications also carry a risk.

Let’s make sure we do it in style and in line with our corporate responsibility guidelines, in particular:

  • Make it yours. Be open about the fact that you’re a Bacardi employee but not an official company spokesperson.
  • Facts must always be honest and accurate. What you say can be seen by anyone all over the world.
  • Show respect for others’ opinions, even when you might not agree.
  • Don’t share our confidential information.

DID YOU KNOW?

Even if you do not work in a Marketing role, when you create social media content about alcoholic beverages you should comply with the standards set by the Principles of Social Responsibility.

WHOOPS!

If you mess up, be quick to correct it and clear about what you did to fix it.Give your manager a heads-up; they’re there to help. If it’s a bigger matter, contact the I.T. Digital Marketing team for help

CORPORATE RESPONSIBILITY

(Charitable Contributions & Sponsorships)

Through the Bacardi Philanthropy and Community Investment (PCI) pillar of our Corporate Responsibility (CR) platform, we support charitable organizations that help us maintain a global sustainable environment for our Company and employees to thrive.As a Bacardi employee, you are encouraged to support charities and participate in events important to your community in four broad areas:

• Arts & Culture•Education•Environment•Health & Social Services

All charitable contributions and sponsorships are to be given appropriately. In particular, they should not be perceived to create improper conflicts and influence , or otherwisesupportpolitical parties and officials.

DID YOU KNOW?

When supporting charitable organizations, you should only be engaging with Legal Drinking Age+ (LDA) audiences.

COMPLIANCE

COMPLIANCE WITH LAWS, RULES AND REGULATIONS

As a Bacardi employee, you must comply with all applicable laws, rules and regulations in the countries where we do business. In the countries where industry codes and practices are applicable by law or agreements on self-regulation, employees are also responsible for compliance with such codes and practices. If you have questions about regulations or codes, it is your responsibility to seek guidance from your line manager, your management team or the Legal/Compliance functions.Do not take any action that you know, or reasonably should know, would violate applicable laws, regulations or codes.

COMMERCIAL PRACTICES

FAIR COMPETITION

Competition laws (often called “antitrust” laws) prohibit actions that limit market competition. Those laws can vary nationally though some basic principles are common. Bacardi supports business competition and competes fairly in all markets.

In order to protect yourself and the Company, understand local competition laws, rules and regulations and ask if you have doubts since these laws are complex and can change. In general, follow these rules:

  • Do not agree with a competitor on actions that have the goal or result of limiting fair competition, whether in writing or orally.
  • Do not share with competitors any marketing, distribution, promotional or pricing plans related to the Company’s businesses.
  • Do not seek or accept confidential information from competitors.

DISTRIBUTION PRACTICE

Many markets have alcohol beverage laws, regulations, and codes (often called “trade practice rules”) regarding the distribution, promotion and sale of our products in local markets.

Trade practice rules govern how alcohol suppliers such as Bacardi can engage in sales and promotional activities with the trade and with consumers.They can regulate channels of distribution (including e-commerce distribution) and restrict the type of value (e.g. POS, incentives, displays, equipment, or other) we can provide to trade customers. They can also specify the handling ofinvoice terms, as well as the age of purchasers.

You need to ensure that our activities and those of our distributors are in compliance with the applicable trade practice rules. The same applies to our promotional agencies and other service providers.

Anti-competitive behaviors are not limited to formal or written agreements (for example, resale price maintenance as well as agreements between competitors to allocate market shares or fix prices) but they can also include informal conversations.

WHAT SHOULD YOU DO IF?...

You are engaged in a conversation with a competitor and suddenly price planning information is discussed.

Politely end the conversation, leave the meeting and report the matter to your inhouse Bacardi Legal counsel immediately.

ENVIRONMENT, HEALTH AND SAFETY

We are committed to protecting the health and safety of all employees. Our Environmental sustainability strategy aims to reduce the impact of our operations across our entire value chain, involving all our employees and our suppliers. We aim to achieve best-in-class environmental and safety performances.

Your role is key in maintaining a safe and healthy work environment.We must all contribute to building a culture of sustainability and safety.

The Company prohibits firearms in its offices and manufacturing facilities. Possession or use of illegal drugs in the work environment will be treated as a serious disciplinary offense.

WHAT TO DO IF...?

You witness a behavior or working environment that creates unsafe working conditions for you, your colleagues, our customers or business partners. Report it immediately to your line manager or your site Health and Safety manager.

DID YOU KNOW?

Our Company is the only major spirits company with “triple crown” certification for quality, environment, and health and safety – for all its production facilities globally – created by the Occupational Health & Safety Advisory Services (OHSAS) and the International Organization for Standardization (ISO), the leading management standards in the world.

ECONOMIC SANCTIONS

Economic Sanctions are restrictive measures taken by a country, a group of countries (e.g. the European Union) or an international organization (The United Nations) which restrict and sometimes prohibit business dealings with specific countries, entities or individuals.

Bacardi must comply with all international and national sanctions and has implemented specific controls to ensure the Company does not infringe them. As part of those controls, you should always conduct due diligence checks on the status of third parties before engaging them with Bacardi in countries that are subject to sanctions.

INSIDER TRADING AND SECURITIES LAW COMPLIANCE

Bacardi is a privately held, family owned company whose common shares are not publicly traded or registered. However, Bacardi does have debt, including bonds, that are sold to third party investors and can be publicly traded. Bacardi information can impact the trading of Bacardi securities or bonds, so care must be takenwhen sharing material Bacardi information before it is made public.

You shall never buy or sell Bacardi securities on the basis of non-public information obtained in the course of your employment, or as the result of improper disclosure. The same principle applies to purchases of securities of other companies by an employee or his relatives based on non-public information you obtain as a Bacardi employee.

ANTI-BRIBERY AND CORRUPTION

Corruption includes bribes, kickbacks, facilitation payment or any illegal inducement which results in a personal gain to the recipient or its associates and is intended to influence them to take action. Bacardi does not tolerate corruption. It is committed to compliance with global best practices and the anti- corruption laws in the countries in which it operates. It expects its business partners and its representatives to fully comply with the Company’s position, including its brokers, agents, consultants, distributors or service providers. This prohibition applies to actions directed at either public officials or private employees of any entity that does business with Bacardi.

RED FLAGS

  • Payments to out -of-country bank accounts.
  • Payments not in line with fair market value, including the value of commission
  • Receipts without proper supporting documentation.
  • Being advised by a government official that Bacardi “needs to” work through a designated distributor or vendor.
  • Requests for payment in cash.
  • Gifts requested by recipient.

If you face or witness any of those situations, you should report the matter to your line manager, the Bacardi Legal counsel or the Compliance function.

WHAT IS A PUBLIC OFFICIAL?

  • The definition of a public official differs from one jurisdiction to another:based on best practice, the following positions are considered as “public officials”:
  • Elected member of a government, or
  • A government employee at the national, state or provincial and local government levels , or
  • An employee from a state owned/ state-controlled company. In this case, the employee of a state-controlled distributor can be considered
    as a public official.

WHAT TO DO IF YOU ARE OFFERED A BRIBE OR A KICKBACK?

If you are offered or asked for any form of bribe, you must categorically refuse it, clearly state our Company position on anti-corruption and report it to the Bacardi Legal counsel or the Compliance function.

SOCIAL RESPONSIBILITY IN MARKETING PRACTICES

Bacardi is committed to marketing and advertising practices that promote responsible and safe consumption of alcoholic beverages by legal drinking age consumers. To this end, we aim to continue to uphold our excellent record of compliance with marketing codes regionally and globally, and to partner with other beverage alcohol players to reduce alcohol-related harm.

As a Bacardi employee, you are expected to act responsibly in the consumption of alcoholic beverages at all times, and particularly in connection with any Bacardi activities.

OUR 9 GLOBAL MARKETING PRINCIPLES FOR SOCIAL RESPONSIBILITY

As a Bacardi employee, you are expected to know those principles, to apply them in a prudent manner and to seek guidance in case of doubt.

ILLEGAL TRADE

We strive to protect our brands from all forms of illegal trade, which is the production, import, export or sale of goods in contravention of relevant laws and regulations. This usually includes transnational trade, contraband and counterfeit or illicit products.

You must never manage or become involved in any illegal trade scheme. If you become aware of any counterfeit or contraband activity involving our products, you must report it to your line manager and your Bacardi Legal Counsel.

THE VARIOUS FORMS OF ILLEGAL TRADE

  • Illegal Transnational or Parallel Trade is genuine product moved across geographical boundaries, without the consent of the brand owner.
  • Contraband is genuine product, imported without payment of applicable duties and other taxes.
  • Counterfeit is fake product, appearing to be a genuine one. Counterfeit products have inferior quality and sometimes toxic content.

Alcohol illegal trade not only leads to billion dollars loss in tax revenue to the governments, consumer deception and damages to our reputation, but also leads to public health risks, as many counterfeit products may be unfit for human consumption.

RELATIONSHIPS WITH SUPPLIERS AND BUSINESS PARTNERS

Suppliers and business partners are selected impartially and objectively, based on criteria that include reputation, integrity, performance and quality. We expect our suppliers and business partners to comply with the law, apply ethical business practices and meet Bacardi standards for integrity, quality and performance.

ABOUT TO SIGN A CONTRACT?

PAUSE! Ask yourself: Am I acting within the scope of my authority and in compliance with the Legal Guidelines and country specific Signature Authority policies?

POLITICAL ACTIVITIES AND CONTRIBUTIONS

Bacardi encourages all employees to be aware and to participate personally in political processes of their choosing. Such participation must be in an individual capacity (i.e. not company), at the employee’s expense and during personal time.In those instances where political contributions by corporations are legally prohibited, individuals are not allowed to make contributions on behalf of Bacardi and employees may not use Bacardi facilities, resources (including emails) or employee time for purposes of political fundraising activities or solicitations.

In any such circumstances, you must declare to your line manager and your Human Resource (HR) Representative if you intend to run as a candidate for public office.

WHAT TO DO IN JURISDICTIONS WHERE CERTAIN POLITICAL ACTIVITIES MAY BE LAWFULLY UNDERTAKEN BY CORPORATIONS?

In the jurisdictions where certain political activities and contributions may be lawfully undertaken by corporations, Bacardi may make political contributions, subject to current legal advice and written approval of the member of the GLT responsible for the operation or function, in consultation with the General Counsel and the Chief Executive Officer. All lawful political contributions by Bacardi must be properly accounted and reported in writing.

In limited jurisdictions Bacardi may operate and support in combination with employees, certain political action committees. Such committees and their actions must comply with all legal requirements, including accounting and reporting requirements. The formation of a political action committee shall be approved in writing by the responsible member of the GLT in consultation with the General Counsel and the Chief Executive Officer.

In the jurisdictions where lobbying activities may be lawfully performed by corporations, Bacardi may engage in such activities, provided they receive the prior written approval of the responsible member of the GLT, in consultation with the General Counsel. All lobbying activities and costs must comply with applicable laws and be properly recorded and reported.

OUR INTERACTION WITH GOVERNMENTS AND MEDIA

GOVERNMENT INQUIRIES AND INVESTIGATIONS

Bacardi is committed to cooperate fully with government inquiries and investigations.

If you receive any communication concerning a possible government action involving our Company, you must immediately bring it to the attention of your line manager and Bacardi Legal Counsel. In case of unannounced visits or inspections by government officials, you should contact immediately your local HR contact, Bacardi Legal Counsel or the General Manager.

MEDIA RELATIONS

External communications on corporate performance and organization, commercial, corporate and brand news releases, media interviews, or any other communication to external audiences publicly by any function/person in the company must have the appropriate approvals and sign-off before issuing.

WHO CAN APPROVE MEDIA COMMUNICATION?

Unless duly authorized by the Chairman of the Board of Bacardi Limited or the Chief Executive Officer, you should not communicate to members of the press any information concerning financial results, financial estimates, transactions, organizational changes, Bacardi family and shareholder matters, or other material items concerning the Company.

Contact the Communications Department for support relating to any issue or situation (e.g. brand, event, program, quality, production facility, employee, office, country, company, vendor, business partner, campaign, etc.).

DID YOU KNOW?

The Global Corporate Communications Department leads all company communications related to external corporate and brand public relations and serves as the clearing-house for important and/or top-tier external media inquiries.

WE ARE HERE TO HELP!

The standards outlined in this Code are by no mean exhaustive and do not replace the Company’s detailed policies and local laws or stricter local Codes of Bacardi subsidiaries. The Code sets minimum standards.

Adherence to the Code is vital to our success and will be strictly enforced. If you are unsure about what to do in a certain situation, we encourage you to go to your line manager or your HR contact or the Compliance team. The role of your Compliance team is to assist you in the everyday application of our Code, as well as to implement compliance programs, lead investigations of alleged noncompliance, and provide periodic reporting to the Compliance Committee.

The Global Compliance Officer

The Global Compliance Officer leads the Compliance Function and has overall responsibility for managing compliance matters.

The Compliance Committee

The Compliance Committee is a standing subcommittee of the Global Leadership Team consisting of the Chief Administration Officer, the Senior Vice President Human Resources, General Counsel and the Global Compliance Officer.

The purpose of the Committee is to:

(i) oversee the Company’s implementation of compliance programs, policies and procedures to manage the compliance risks facing the Company; (ii) assist the Audit Committee of the Board in fulfilling its oversight responsibility for the Company’s compliance and ethics programs.

The Compliance Committee provides periodic reports to senior management and the Audit Committee.