The way we work,

every day, everywhere

The way we work,every day, everywhere

ur purpose and values define what is important in the way that we work together and perform as a business.

We are intent on constantly demonstrating our commitment to being one of the world’s most trusted and

respected companies. We ask our consumers, shareholders, governments and the communities in which we operate,

to trust that we understand our responsibility as the world’s leading premium drinks business and that we

behave accordingly.

Reputation is critical to Diageo’s commercial success, long-term sustainability and fulfilment of our purpose of

celebrating life every day, everywhere. We all have a responsibility to ensure we strive to do the right thing and in so

doing, protect that reputation. In today’s connected world our individual actions have the potential to impact Diageo

globally, both positively and negatively. All of us, including those acting on behalf of Diageo, have an obligation to

apply the Code of Business Conduct, Diageo policies, and all relevant laws, in everything we do.

In producing this update of the Code our aim has been to provide a clear and accessible document with practical

guidance on our individual responsibilities and how to access further sources of information. The Code is now

available in 18 languages, reflecting the geographical breadth and multi-cultural nature of our operations.

However, such a code cannot address every situation we may face and it is not a substitute for applying common

sense and good judgement, informed by our purpose and values and our commitment to being one of the most

trusted and respected companies in the world. When in doubt, seek advice; talk to your colleagues to get their

perspective. Talk to your line manager, our Global Compliance & Ethics Director or an expert from the

appropriate function.

If you are concerned about something that does not appear to support our purpose and values or contravenes the

law, the Code, or Diageo policies, you should speak up. There may be circumstances in which you may wish to use the

independent SpeakUp service, where you can raise an issue or concern confidentially.

We will not tolerate any retaliation against an individual for raising a concern or making a report in good faith.

We want Diageo to be recognised as a great place to work. Most of all, however, we want Diageo to become

a by-word for acting with integrity and responsibility; a business with values that are demonstrated every day and are

deeply embedded in the fabric of the organisation.

Please take the time to read and understand the Code. Please also personally commit to implementing it in all of

your actions and all of our business activities. We know that we have your full support for the values that have set

Diageo apart from the competition. Thank you.

Paul S Walsh

Chief Executive

Ron AndersonChief Customer Officer

Gilbert GhostineManaging Director, Continental Europe

Randy MillianManaging Director, Latin America and Caribbean

Nick C RoseChief Financial Officer

Nick B BlazquezManaging Director, Diageo Africa

David P GosnellManaging Director, Global Supplyand Global Procurement

Andrew MorganPresident, Diageo Europe

Larry SchwartzPresident, Diageo USA

Andrew J FennellChief Marketing Officer

Jim N GroverDirector, Global Business Support

John C PollaersPresident, Diageo Asia Pacific

Gareth WilliamsHuman Resources Director

Stuart R FletcherPresident, Diageo International

Ivan M MenezesPresident, Diageo North America and Chairman, Diageo Asia Pacific

Timothy D ProctorGeneral Counsel

Ian WrightCorporate Relations Director

O

Letter from the Executive Committee

INTRODUCTION

Our purpose & values 5

Code of Business Conduct 6

Getting help & advice 7

The way we work 9

OUR PRODUCTS

Marketing & innovation 11

Quality 12

International trade & free zone sales 13

PERSONAL INTEGRITY

Gifts & entertainment 15

Conflicts of interest 16

Insider trading 17

COMMERCIAL INTEGRITY

Bribery & improper payments 19

Competition & anti-trust 21

Money laundering 23

Accurate reporting & accounts 24

Data privacy 25

EMPLOYMENT

Health, safety & security 27

Discrimination & harassment 28

Responsible drinking 29

COMPANY ASSETS

Brand protection 31

Confidential information 32

Information security 33

Records management 34

EXTERNAL ACTIVITY

External communications 36

Political activity 37

Community & charitable activity 38

Human rights 39

Environment 40

CONTACTS

Contacts & links 42

SpeakUp 43

CONTENTS

INTRODUCTION

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We are passionate about

consumers – our curiosity and

consumer insights drive our

growth. We cherish our brands;

we are creative and courageous

in pursuing their full potential.

We are innovative, constantly

searching for new ideas.

We give ourselves and each

other the freedom to succeed

– we trust each other, we are

open to and seek challenge,

and we respond quickly to

the opportunity this creates.

We are proud of what we

do – we behave responsibly

with the highest standards

of integrity and social

responsibility.

We strive to be the best – as

an organisation we are never

complacent. We are always

seeking to learn and improve.

We value each other – we

seek and benefit from diverse

people and perspectives.

We strive to create mutually

fulfilling relationships and

partnerships.

Our purpose, to celebrate life every day, everywhere, and our values lie at the heart of our business.

They define our approach to the way we work. They capture the essence of our passion, our

ambition, our responsibility and our pride in what we do.

Our values reflect our beliefs about what is important in the way that we work together and

with others outside of Diageo. We bring them to life in our business, every day, everywhere,

through the way we behave and the results we achieve. Our values should be our guide when

making decisions and deciding priorities.

To reinforce our behaviours we have established codes and policies, setting out the way we

work, our commitments and what is expected of each of us. These policies can be found on

the Diageo intranet and you have a responsibility to comply with them.

This document, our overall Code of Business Conduct, is designed to help translate our values

and principles into actions and guide our daily activities.

Each of us needs to take time to read and understand the Code and use it to help us apply

our values in everything we do.

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Our purpose & values

Our purpose and values are at the heart of everything we do – influencing the way we work, every day, everywhere

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Why do we need a Code

of Business Conduct?

The Code sets out

Diageo’s commitment

to conducting business in

accordance with our purpose

and values, all relevant laws

and regulations and industry

standards. It provides guidance

on what is expected of each of

us and references other Diageo

policies and guidelines.

Failure to comply with the

Code or any Diageo policy is

treated very seriously and may

result in disciplinary action,

including dismissal.

Does the Code apply

to everyone in Diageo?

The Code applies to

everyone working for

Diageo worldwide regardless

of location, role or level

of seniority.

It also applies to anyone

working on behalf of Diageo.

All agents and representatives,

consultants, contractors and

temporary employees are

required to comply with the

Code and to report any actual

or potential violations of

the Code or Diageo policies

through one of the routes

described in this document.

Every non-wholly-owned

subsidiary and joint venture

which Diageo controls should

adopt a code of business

conduct and policies aligned

with those of Diageo. Where

we participate in, but do

not control, a joint venture

relationship we will encourage

our partners to meet the

requirements of the Code in

both the joint venture and

their own operations.

We strive to demonstrate the highest standards of integrity in the way we behave towards each

other and to those outside of the company. Our actions and interactions with our consumers,

customers, employees, public officials, suppliers, shareholders and other stakeholders should

clearly reflect our commitment to doing the right thing. Reputation is critical to our commercial

success and can only be enhanced by behaviours of which we can all be proud.

The Code of Business Conduct provides information on key areas of our business activities and

outlines our individual responsibilities – the things we must all do. All employees and those

acting on behalf of Diageo must apply the Code and Diageo policies that relate to their role,

regardless of their location or nature of work. It is critical that we all familiarise ourselves with

the Code and policies and apply them to everything we do.

Breaching the Code or Diageo policies can have serious consequences for the company and

for each of us as individuals. Those who fail to follow the Code put themselves, their colleagues,

and Diageo at risk. This is taken very seriously and may result in disciplinary action up to and

including dismissal.

The Code cannot provide answers to every question we may have or tell us what to do in every

situation in which we may find ourselves. It does not serve as a substitute for our individual

responsibility for exercising good judgement and common sense. It is a resource to be used

to help guide our actions and provides details on where to go to for more information on

a particular subject, to ask questions, or to report a problem.

Responsibility for compliance & ethicsEach Diageo employee is responsible for compliance with the Code of Business Conduct

and Diageo policies in addition to all laws, regulations and industry standards. The company

places its trust in each of us to act in a way which is not only compliant but which supports our

values, purpose and business principles.

The Global Compliance & Ethics team manages the Diageo Compliance & Ethics programme

and is there to provide help and guidance on all issues relating to the Code and Diageo policies.

If you manage people, you are expected to adopt the Diageo Leadership Standard and be

a role model for others. You must ensure that the individuals who report to you receive the

guidance, resources and training they need to enable them to do their job in compliance

with the Code and Diageo policies. You must take personal accountability for creating an

environment of trust in which people feel able to ask questions, raise concerns and report

suspected violations without fear of reprisal. There will be disciplinary action for all levels

of management for lack of diligence, supervision or leadership with regard to the application

of the Code and Diageo policies.

All agents and representatives, consultants, contractors and temporary employees are required

to abide by the Code and Diageo policies. If you work with agents or representatives, or you

engage an individual on a non-permanent basis, it is your responsibility to ensure that they

have been provided with a copy of the Code and understand what is expected of them.

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Proud of what we do, proud of how we do it

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Does the Code contain

everything I need to

know in doing my job?

No, the Code cannot detail

everything you need to

know in doing your job or every

situation that you may encounter.

You are responsible for learning

about and conducting your

work in accordance with

Diageo’s values, the Code

and Diageo policies, and all

applicable laws.

Diageo operates across many

different countries each of

which has its own local legal

system. You need to ensure

you understand and comply

with local laws and regulations,

in addition to the Code and

Diageo policies.

Other Diageo policies and

guidelines, not specifically

referred to in the Code that

may be relevant to your

job can be found on the

Diageo intranet.

As a manager do I have

additional responsibilities?

Yes. If you are responsible

for managing people, you

must lead by example and act

as a role model for others. You

need to ensure that anyone

who reports to you receives

guidance and training and the

resources they need to protect

themselves and Diageo.

You are responsible for creating

an environment of trust that

encourages open discussion

about compliance or ethical

concerns and where people

feel able to report suspected

violations without fear

of reprisal.

If you are involved in retaining

third parties to act on behalf of

Diageo, you must ensure that

they are made aware of and act

in accordance with the Code

and Diageo policies.

Every day we face situations that may be unfamiliar to us or where we are unsure as to the best

course of action to take. We naturally turn to those we work with and trust to seek support

and guidance in doing our job. Applying the Code, Diageo policies, and laws and regulations

to our daily work is no different. No one is an expert in all matters or intuitively knows what to

do in every situation.

Whenever we are unsure about the areas raised in this Code or any other matter, it is the right

thing to do to ask questions and seek advice. In some instances it may simply be a case of

confirming that the action we intend to take is the right one and in line with Diageo’s purpose

and values. In others, it may be that we believe something to be taking place which is in

breach of the Code or Diageo policies or may even be illegal.

In any of these instances we should speak up. Where we believe there to be a violation

of the Code, Diageo policies, or the law, we have an obligation to report the matter promptly

through one of the routes described in this document. This is the case even where we do not

necessarily have all the facts, as long as the report is made in good faith.

Guidance is given throughout the Code as to who you can ask for further information or advice

on particular subjects. On all matters you can go to your line manager to ask for help, raise an issue,

or check on the right course of action.

There may be occasions where you would prefer to speak to someone else in the first instance.

In such situations, you can contact the Global Compliance & Ethics team, Legal or HR teams.

The Global Compliance & Ethics team is there to answer your questions and can provide

advice on who to contact regarding a particular subject. You can also contact them directly to

report matters about which you are concerned. The team work closely with all other Diageo

functions and will know who to inform or consult further on any matter you raise. They can be

contacted on global.compliance.programme@diageo.com.

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Getting help & advice

None of us knows the answer to every question or what to do in every situation – we all need help and advice

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I don’t want to bother

my line manager with lots

of questions. What things do I

really need to talk to him about?

Your line manager is there

to help you with any matter

related to the Code and Diageo

policies on which you would

appreciate advice or if you are

unsure about the right thing

to do.

Where you believe that a law,

regulation or policy is or may

be being broken you must

report this. Your line manager

is generally your first point of

contact in such cases. However,

there are other channels

available to you – the Global

Compliance & Ethics team,

Legal or HR teams, or SpeakUp

– if circumstances are such that

you would prefer to speak to

someone else.

I’m thinking of contacting

SpeakUp about something

happening in my team but I’m

worried my line manager will

find out it was me who made

the report. Will he be told?

Each report made

through SpeakUp is

handled confidentially. When

you make a report you are

given the option to remain

anonymous. However,

disclosing your name is likely

to make it easier to conduct a

thorough investigation. Your

name will be kept confidential

unless we are required to

disclose it as a result of legal

proceedings or a government

investigation.

Diageo will not tolerate any

retaliation against an individual

for raising a concern, making

a report or assisting in an

investigation.

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SpeakUp is a resource for all of us to use to raise areas of concern about compliance and

ethics matters, or to make a report when we think a policy or law is being broken, or when

something doesn’t feel right.

SpeakUp is managed by an external company, independent from Diageo, with staff who

are trained to deal with your call, and translators who are immediately available to assist

if required.

Issues to report can include knowledge of, or reasonable suspicion of, violations of legal,

accounting or regulatory requirements, breaches of the Code or Diageo policies, or any

questionable conduct or practice.

Telephone numbers for SpeakUp and details of alternative ways of contacting the service can

be found in the Contacts section of this document and on the Diageo intranet.

If you feel more comfortable doing so, you can call anonymously. If you give your name,

it will be kept confidential unless required to disclose it as a result of legal proceedings

or a government investigation.

When you contact SpeakUp, the external company will promptly send a confidential report

to Diageo’s Global Compliance & Ethics Director who will follow up and ensure the issue

is appropriately investigated. You will be given a unique report number which you can use

to check on the action being taken in response to your report. Dependent on the nature

of the issue, a formal investigation may be initiated.

Diageo will not tolerate any reprisal for reporting a problem or assisting in an investigation.

Anyone found to be involved in retaliation against an individual who has raised a concern

will be subject to disciplinary action.

The important thing is to speak up.

We are all expected to:• Speak up if we are unsure what to do in a situation and ask for help and guidance from

our line manager or relevant Diageo team.

• Always report promptly anything which we believe to be unlawful or in breach of the

Code or Diageo policies.

• Forward reports which we receive of potential or actual breaches to the Global Compliance

& Ethics team who will provide guidance and support and initiate an appropriate response.

Getting help & advice (continued)

Diageo SpeakUp

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How should I handle

situations not covered

by the Code?

You may face situations

which are not explicitly

covered by the Code and

you are unsure of the correct

course of action to take. In such

situations it can be helpful to

ask yourself some questions:

• Is the action legal?

• Does it support

Diageo’s values?

• Could it expose Diageo

to unacceptable risk?

• Does it comply with the

spirit of the Code and

Diageo policies?

• How would it appear to

others – your line manager,

colleagues or family?

• Would you be comfortable

if it was reported in

a newspaper?

• Does it feel right?

If you still have concerns,

seek guidance – from your line

manager, Global Compliance &

Ethics team, Legal or HR teams

or contact SpeakUp.

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Our purpose and values drive the way we work and define our business principles which are

inherent in everything we do, every day, everywhere. We are committed to:

• conducting our business in accordance

with all relevant laws, regulations and

industry standards

• complying with all laws and regulations

governing the import and export of

our products, including those related to

customs, tax, duty free sales, embargoes

and anti-boycott requirements

• conducting business in a manner which

is honest, sincere and trustworthy

• acting in a truthful and co-operative manner

in all government or legal investigations

or those conducted internally

• monitoring and reporting on our

compliance with all relevant laws,

regulations and industry standards

• ensuring every non-wholly-owned

subsidiary and joint venture which

Diageo controls adopts a code of business

conduct and policies aligned with

those of Diageo

• encouraging our partners in the joint

ventures that we do not control to meet

the requirements of the Code in both the

joint venture and their own operations

• expecting our agents, representatives and

consultants to comply with the Code and

Diageo policies and report any violations

• actively encouraging our suppliers to

meet the requirements of the Code and

Diageo policies in their own operations.

We are all expected to:• Learn about and comply with the laws, regulations and Diageo policies which apply to our job.

• Always seek advice and guidance if we are unsure about the course of action to take

and encourage others to do the same.

• Be alert to and report any issues or potential violations to our line manager, Global

Compliance & Ethics team, Legal or HR teams or contact SpeakUp.

• Never judge or retaliate against an individual who raises an issue, reports a violation

or participates in an investigation.

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The way we work

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You can get further advice and support regarding marketing and promotional activities from your line manager,

Marketing team, Corporate Relations team or Global Compliance & Ethics team.

The Diageo Marketing Code and the Digital Code of Practice contain further information and guidance

on this subject.

Don’t forget, you can always discuss concerns or make a confidential report using SpeakUp.

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I’ve been working on a marketing campaign for a new product. I’m concerned that some of the things we are saying are not entirely accurate. Should I raise the issue or not worry about it?

You should express

your concerns to your line

manager. No matter how small

or insignificant the inaccuracy

may appear it could be very

damaging to Diageo’s reputation.

We have a responsibility to our

consumers to ensure that our

marketing is always truthful

and accurate.

I have received a small

number of complaints both

internally and from the public

that a recent local advertising

campaign is culturally insensitive.

I don’t agree. Should I just

ignore them?

No, notify your line manager

and your Corporate

Relations team who will help to

determine the best course of

action. In addition, as a matter

of course, any Diageo business

that receives criticism of its

marketing activities should

inform the Diageo Corporate

Relations team in London

immediately.

Digital media, such as websites, email and mobile phones provide us with new and dynamic

ways to market to our consumers. The core principles of the Diageo Marketing Code apply

equally to digital marketing and more traditional methods. To provide further guidance, the

Digital Code of Practice has been developed to address specific standards for all of Diageo’s

digital and promotional marketing activities.

We are all expected to:• Apply the Diageo Marketing Code and Digital Code of Practice to all marketing and

promotional activities.

• Ensure all marketing activities are in keeping with both the letter and the spirit of all

applicable national laws.

• Follow the approval process for all marketing activities as specified by our Diageo business

unit and as detailed in the Diageo Marketing Code.

• Pay special attention to applying both the Diageo Marketing Code and Digital Code

of Practice to digital advertising and promotional activities.

• do not target consumers under legal

purchase age

• do not depict alcohol consumption in

unsafe situations or before/during any

activity that requires concentration

• do not encourage or condone excessive

or irresponsible consumption

• do not use high alcoholic content as a

dominant theme

• do not associate our products with violence,

anti-social behaviour or offensive themes

• do not promote alcohol as a medicine, or

suggest that it enhances performance or

sexual attractiveness, or is a requirement

for social acceptance or success.

We are proud that our brands bring pleasure to millions of adults every day, all over the world,

playing a unique part in the social lives and celebrations of many cultures.

We are also passionate about our consumers and we recognise that alcohol beverages may be

consumed irresponsibly, creating problems for the individual and for society. We must ensure

that our brands are advertised and marketed responsibly.

The Diageo Marketing Code applies to all of our activities that communicate about and market

our brands. Central to it are that we:

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We want Diageo’s marketing and promotionalactivities to be recognised as the best in the world

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You can get further advice and support regarding quality matters from your line manager or the Global

Compliance & Ethics team.

The Diageo Quality Policy contains further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confidential report using SpeakUp.

A

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We have received a

report from a supplier

that contamination may

have occurred in a recent

shipment of ingredients. The

products which contained the

ingredients have already been

shipped to the customer. We

have no definite evidence of

contamination. Do we need

to recall the products?

We have a duty to respond

promptly to any concerns

about product quality or safety,

even if that requires the recall

of products. You should raise

the issue immediately with

your line manager who will

determine the appropriate

course of action.

I work on the production

line and I’ve noticed

some defective finished goods

that are not within our normal

tolerance levels. I’ve mentioned

it to my line manager but he

has told me not to worry as the

defect is minor. Is he right?

No, he is not right.

We strive to achieve the

highest standards in everything

we do. We want our customers

to enjoy the best products we

can produce and even a small

defect could compromise this

and potentially do damage

to our reputation. You should

contact the Global Compliance

& Ethics team directly or

call SpeakUp to report your

concerns.

We want to be the best and are passionate about ensuring our products are consistently

of the highest quality. Our consumers should be able to trust in the quality, safety and purity

of our beverages.

The Diageo Quality Policy applies to all Diageo brands and associated products and covers

all aspects of the supply chain from vendors to consumers.

The standards set out in the policy apply to all Diageo businesses and joint ventures

and should also be referred to when dealing with third party contractors and suppliers.

All our vendors must meet our Quality Risk Management Standards. We mark our products

to allow traceability throughout their storage and distribution.

To ensure that we can properly respond to consumer enquiries and concerns, all Diageo

businesses must have a consumer contact system and procedures to facilitate recall

of products from consumers and resellers if necessary.

All our sites are expected to drive improvements in quality performance, reduce quality

risks and ensure regulatory compliance through the application of the Diageo Quality

Policy and standards.

We are all expected to:• Adhere to the Quality Risk Management Standards where they apply to our work.

• Always strive to ensure that our brands and associated products are safe for our employees,

customers and consumers.

• Ensure that business partners, including vendors and third party producers are managed

according to the Diageo Quality Policy.

• Follow the quality management system as implemented within our business unit or location.

• Demonstrate our commitment to our core values, ‘Be the Best’ and ‘Passionate about

Consumers’ through an unremitting focus on quality in everything we do.

Quality

We are committed to enhancing and protecting our brands through application of the highest quality standards

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You can get further advice and support regarding international trade & free zone sales from the Legal team

or Global Compliance & Ethics team.

The Diageo Customer Management Guidelines contain further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

A

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There is parallel product

in my market (sometimes

called grey market product –

product that has not been sold

in the market by the in-market

Diageo company or a local

Diageo distributor). Can I tell

customers where they can

buy some?

No, our employees and

agents must not be

involved in the delivery

or sale of parallel product.

We have a lot of parallel

product in our market. I

would like to instruct Diageo’s

free trade zone distributors

not to sell to customers who

might end up re-exporting

the product to my market.

Our free zone distributors

are required to comply

with all applicable laws and

to adhere to the terms of their

contracts with Diageo. As long

as they abide by all legal and

contractual requirements,

Diageo employees should

not instruct our free zone

distributors where our

products should or should

not go.

We comply with all laws and regulations governing the import and export of our products,

including those related to customs, tax, duty-free sales, embargoes, and anti-boycott

requirements. Likewise, Diageo requires our free trade zone distributors, who sell our products

for general re-export out of the country where their free zone is located, to comply with all

applicable laws and regulations.

Diageo products – like those of many other consumer goods companies – are sometimes

smuggled into markets by third parties without full payment of duties. Our people must not

manage, promote, or otherwise allow themselves to become involved in this trade.

You can get further advice and support regarding international trade and free zone sales from

the Legal team or the Global Compliance & Ethics team.

The Diageo Customer Management Guidelines contain further information and guidance

on this subject.

We are all expected to:• Comply with all laws and regulations governing the import and export of our products.

• Never manage, promote, or otherwise allow ourselves to become involved in the

smuggling trade.

• Seek guidance from the Legal team if in any doubt as to our commitments in regard to

international trade & free zone sales.

International trade & free zone sales

Sales to Diageo customers must be in full compliance with applicable laws

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Gifts & entertainment

The gifts & entertainment we give or receive should never create improper influence or give the impression of doing so

A

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You can get further advice and support regarding the giving and receiving of gifts and entertainment from your

line manager, Legal team or the Global Compliance & Ethics team.

A Gifts & Entertainment Register template can be downloaded from the Diageo intranet or is available

from the Global Compliance & Ethics team.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

I would like to buy a gift

for a supplier. I think it

will be difficult and time-

consuming to organise the

purchase through Diageo. Is it

okay if I buy the gift using my

own money and then claim it

back on expenses?

Any gifts or entertainment

given or received must

not only be recorded in your

Gifts & Entertainment Register

but also properly accounted

for within the appropriate

company records. Even if you

choose to buy the gift at your

own expense and not claim

this back, you are still offering

the gift in your capacity as a

representative of Diageo. You

must therefore ensure that you

seek the prior approval of your

line manager if required and

that the expense is properly

recorded.

I have been invited to

the wedding of the

daughter of a local government

official. In my culture it is

expected that guests will give

cash gifts at the wedding.

Given the circumstances is

a cash gift acceptable?

Diageo is a global company

and we will encounter

cultural differences to which

we have to be sensitive.

However, providing cash gifts

is prohibited regardless of the

circumstances. It exposes the

company and our employees

to unacceptable risk. Offering

an appropriate non-cash gift

may be acceptable in these

circumstances but you must

discuss the matter with the

Legal team and get their prior

written approval before giving

any gift.

The giving and receiving of gifts and entertainment have a role to play in building business

relationships and generating goodwill. However, they should never create improper influence

or obligate the recipient. We should not provide or accept excessive or inappropriate

entertainment and must only ever offer or accept gifts of modest value.

Reasonable business-related entertainment that is conducted in the interests of Diageo can be

provided or accepted if it is modest and occasional. You should seek your line manager’s prior

approval before accepting or offering any entertainment which could be regarded as excessive.

We must never offer or accept gifts of cash or cash equivalents such as gift certificates, loans,

stock, or stock options.

Gifts that we give should be of nominal value and preferably display a Diageo brand. Diageo

discourages the acceptance of gifts by employees, except where this is clearly related to

a business purpose. You must inform your line manager if in any 12 month period, you intend

to give or receive:

• gifts exceeding a value of £100* to or from any one entity or

• gifts exceeding a value of £250* in total.

Particular caution should be applied in any dealings with government officials. No gifts or

entertainment may be given to, or paid for on behalf of, any government or military official,

without the prior approval in writing of the Legal team.

We each have a responsibility to keep a record of the gifts and entertainment which we

give or receive. This does not include nominal value items, such as promotional items or

working meals. Local policy will determine the cost threshold for recording items. A Gifts &

Entertainment Register template can be downloaded from the Diageo intranet or is available

from the Global Compliance & Ethics team. Registers will be regularly reviewed to ensure they

are up to date and accurate.

* Or a lower value as specified by the Diageo Regional President as being appropriate for a particular country.

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We are all expected to:• Ensure details of all gifts and entertainment that we either give or receive are recorded

on a Gifts & Entertainment Register.

• Report to our line manager any gifts or entertainment offered to us that exceed the values

specified above, or lower values applicable in our country.

• Always consider whether the gifts or hospitality being given or received could lead to

or imply any obligation.

• Consider the customer’s, supplier’s or other third party’s policies regarding the acceptance

of gifts or entertainment before offering them.

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I have built up a good

relationship over the

years with one of our suppliers

and I’ve been asked if I’d be

interested in investing in the

company. I think it would be

a good investment as I’ve

been impressed by their high

standards. Is there any conflict

of interest here?

This may be a conflict of

interest depending upon

the nature of your role and the

level of influence you have in

selecting suppliers. You should

discuss the situation with

your line manager or Global

Compliance & Ethics team

before committing to

any investment.

My nephew is looking

to move jobs and there

is an open position within my

team for which I think he would

be perfectly suited. I’m worried

about suggesting him though,

given our relationship. What

should I do?

If you feel that your

nephew is well qualified

for the position and would

be a good addition to

the department you are

encouraged to mention this to

the hiring manager or relevant

HR contact. However, you

should have no involvement

in the recruitment process and

the position should not be one

which you directly supervise.

We all owe a duty of loyalty to Diageo. Where our personal, social, financial or political activities

interfere or could interfere with our loyalty to the company, a conflict of interest may exist.

Even the appearance of a conflict of interest can be damaging.

Conflicts of interest can arise in many ways and we should always consider carefully situations

in which our loyalty may be divided.

The activities of family members or close relatives can cause conflicts. If a relative works for

a customer, supplier or competitor, you must disclose this to your line manager. You should

never be in a situation where you are able to hire, supervise, or affect the terms and conditions

of a close relative.

Outside employment and affiliations can result in conflicts of interest, for example, serving as

an officer or director, or acquiring or maintaining an ownership interest in a customer, supplier

or competitor of Diageo.

Improper use of company assets can also be regarded as a conflict of interest. This may

occur when an individual deliberately uses Diageo property or information for personal

benefit or for the benefit of family or friends. Equally, using Diageo property or technology

irresponsibly or for more than incidental personal use is in conflict with the interests

of the company.

Many actual or potential conflicts of interest can be resolved in an acceptable way for both

the individual and the company. The important thing is to highlight the potential conflict to

your line manager, Global Compliance & Ethics team or the Legal team so that an appropriate

course of action can be agreed.

We are all expected to:• Avoid situations where our personal interests may conflict with those of Diageo.

• Always disclose any conflicts of interest or potential conflicts of interest to our line manager.

• Never use our position within Diageo for personal benefit or to benefit a family member.

• Safeguard and use Diageo assets appropriately.

Conflicts of interest

We must not allow personal or family interests to lead us to do anything which is against the best interests of Diageo

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You can get further advice and support regarding confl icts of interest from your line manager, Legal team,

or the Global Compliance & Ethics team.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

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I am PA to one of the

directors within the

company and as such I have

access to quite a lot of

confidential information,

although I don’t tend to read

any of it in detail. I’d like to sell

some of my Diageo shares

but one of my colleagues

suggested that I might not be

able to because I have access

to ‘inside information’.

Is this true?

If you have information

which is not generally

available to the public and

which could affect the

share price or influence an

investor, you may have inside

information. However, it is not

always the case that non-public

information would be regarded

as inside information. You

should ask your line manager,

Company Secretarial or Legal

team for advice.

I know that I am

in possession of inside

information and therefore am

at times restricted in buying or

selling Diageo shares. However,

my brother has mentioned that

he’d like to buy some shares

in Diageo. I never talk to him

about my work so is this okay?

You should be cautious

in this situation and

be clear that there is no

information you have ever

disclosed to your brother

which could be viewed as

inside information. You should

discuss the situation further

with Company Secretarial or

the Legal team.

Trading on the basis of ‘inside information’, often known as ‘insider trading’ or ‘tipping’

is a criminal offence in the UK, US and many other countries.

Information about any listed company which is not generally available to the public and which

could affect the market price of the securities of that company is inside information. Equally,

anything to which a reasonable investor would attach importance in deciding whether to buy,

sell or retain such securities, is also inside information, if it is not publicly known.

It is each individual’s responsibility to ensure that they do not breach insider trading rules.

The Diageo Dealing in Securities Code exists to help ‘insiders’ in this.

You must not buy or sell Diageo securities (stock or bonds) or those of any other listed company

if you are in possession of inside information. Nor should you ask another person to do so on

your behalf or advise others to do so on the basis of such information.

In addition, you should never be involved in spreading false information or engaging in activities

designed to manipulate the price of publicly listed securities, known as ‘market abuse’.

If you have what may be inside information and are considering trading in a Diageo security

you should contact Company Secretarial or the Legal team for advice.

We are all expected to:• Never buy, sell or engage in any other dealings in Diageo securities while being in

possession of inside information. This applies even after leaving Diageo’s employment.

• Never engage in any dealings involving any other company while in possession of inside

information or confidential information about that company.

• Never engage in market abuse by spreading false information or engaging in other activities

designed to manipulate the price of publicly listed securities.

• Refer to the Diageo Dealing in Securities Code and seek guidance from Company

Secretarial or the Legal team before trading in Diageo securities, if there is a possibility

of being in possession of inside information.

Insider trading

We must not trade Diageo or any other securities on the basis of ‘inside information’

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You can get further advice and support regarding insider trading issues from your line manager, Company Secretarial,

the Legal team or the Global Compliance & Ethics team.

The Diageo Dealing in Securities Code contains further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

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You can get further advice and support regarding issues of bribery and improper payments from your line

manager, the Legal team or the Global Compliance & Ethics team.

The Diageo Anti-bribery & Corruption Guidelines contain further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confidential report using SpeakUp.

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I was told I have to pay

a gratuity to a minor

government official to get

our products cleared through

customs. We are under

pressure to get the delivery

to the customer as soon as

possible and it’s not against

the law in my country.

What should I do?

Diageo must not provide

gratuities to officials to

ensure execution of official

duties. The UK Anti-terrorism,

Crime & Security Act makes

it illegal to pay ‘facilitating’

or ‘grease’ payments for UK

companies. Even in countries

where these payments are not

against the law, Diageo strictly

prohibits them. Seek the advice

of your line manager or the

Legal team to determine legally

acceptable alternatives to

secure the release of the goods.

I’ve been told that the

best way to get the

permits I need from a foreign

government is to hire a

consultant to take care of it for

me. I’ve met him and he’s asked

for $50,000 as a retainer. Do I

need to worry about what he

does with it, as long as we get

the permits?

Yes, you have a

responsibility to ensure

that anyone acting on Diageo’s

behalf is not engaging in

bribery or making improper

payments. You must be able to

account for the monies being

spent and ensure that they are

being used for legitimate and

legal purposes.

Diageo will not condone, under any conditions, the offering or receiving of bribes or any other

form of improper payments, including what are known as ‘facilitating payments’. Even the

appearance of a breach of anti-bribery or anti-corruption laws could do significant damage to

Diageo’s reputation. You should exercise particular care in dealings with government officials

to ensure there can be no suggestion of impropriety.

You should not give or promise anything, for example, money, services, gifts, excessive

entertainment or loans that are or could be construed as intending to influence the decision

of customers, suppliers, government officials or political representatives. In addition, Diageo

will not permit the use of intermediaries, agents, subsidiaries or joint venture companies

to give, or promise to give anything to such people on behalf of Diageo or yourself.

No payments, gifts or entertainment may be given to, or paid for on behalf of, any government

or military personnel or other official without the prior approval in writing of the Legal team.

We must never offer gifts of cash or cash equivalents, such as gift certificates, loans, stock,

or stock options to anyone.

Most countries have laws which make it illegal to engage in bribery and corruption. Diageo is

listed on the UK and US stock exchanges and consequently, all of our operations, regardless

of their location, are subject to certain UK and US legislation, in addition to any local laws and

regulations. A breach of any of these laws is a serious offence which can result in fines for the

company and imprisonment for individuals.

US authorities apply the US Foreign Corrupt Practices Act (FCPA) to non-US firms, such as

Diageo, that issue publicly traded securities in the US. The law prohibits the bribery of foreign

officials and Diageo employees must comply with the provisions of the FCPA in all countries

in which Diageo operates. Contravention of the Act can result in severe penalties for the

company and for individuals.

Diageo companies across the world are also subject to the UK Anti-terrorism, Crime & Security

Act which makes it illegal to pay ‘facilitating’ or ‘grease’ payments. These are small payments

or gifts given to a government official in order to get the official to do something legal, for

example, release a cargo shipment where all the paperwork is in order and there is no legal

reason for the official to delay the release.

It is important to recognise that any improper activity or suggestion of improper activity in any

country in which Diageo operates can have implications for Diageo globally. If you are in any

doubt as to the appropriateness of a payment, or transfer of anything of value, which you are

considering making or authorising you should contact the Legal team or Global Compliance

& Ethics team before acting.

Bribery & improper payments

We must never offer or accept money or anything of value to induce or reward favourable treatment for Diageo

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You can get further advice and support regarding issues of bribery and improper payments from your line

manager, the Legal team or the Global Compliance & Ethics team.

The Diageo Anti-bribery & Corruption Guidelines contain further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confidential report using SpeakUp.

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We are all expected to:• Never offer or accept bribes, including ‘facilitating payments’ or any other form of

improper payments.

• Never make, offer or promise to make a payment or transfer anything of value, including

the provision of any service, gift or entertainment, to government, military personnel or

other officials, without the prior written approval of the Legal team.

• Never solicit or accept any gift, payment or other advantage from any person

in return for providing any improper business or other advantage.

• Never do anything to induce or facilitate someone else to breach these standards and

always report any violations or suspected violations.

Bribery & improper payments (continued)

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I bumped into the

Marketing Director of a

competitor at a conference and

we got talking. He asked me

how we were finding the market

and whether we thought we

could increase prices this year.

What should I do?

You have to be very clear

with the individual that

you are not prepared to discuss

pricing or anything else of a

confidential commercial nature.

In negotiations with a

large customer they made

it clear that they will not accept

any price increase from us until

they know when they will see

retail price increases on the

shelves in other retailers.

What should I do?

Explain that you will not

discuss the confidential

terms or pricing plans of their

competitors and that to do

so would be illegal. If the

customer persists, you should

contact the Legal team who

can help to resolve the issue.

Diageo operates within the laws and regulations of each country in which we operate. This means

that we must comply with all anti-trust and competition laws which apply to our business.

These laws which regulate dealings with competitors, customers, distributors and other third

parties are different around the world. Depending on where you work, the laws that apply to

you may vary.

It is important to be aware that these laws can cover conduct outside the country. For

example, some competition laws, such as the US and EU anti-trust laws, can apply even when

the conduct occurs outside the borders of the relevant country or countries.

The penalties for breaching competition and anti-trust laws can be severe with large fines

and potentially prison sentences for those convicted of anti-competitive behaviour.

You must familiarise yourself with and always follow the guidelines on competition and

anti-trust laws for your particular market.

In addition, we should always deal honestly and fairly with all our consumers, suppliers,

employees, competitors and other stakeholders. We should not misrepresent material facts

or use deceptive practices to gain unfairly.

CompetitorsCompetition laws around the world prohibit agreements with or soliciting of agreements

with a competitor to fix prices, set any terms of sale, production levels, divide up markets,

customers or territories, or to boycott any customer. Such communication with competitors

through intermediaries (customers, suppliers or consultants) is also prohibited.

Contact with competitors in the context of social engagements, trade associations or industry

advertising codes must not involve discussion of the areas highlighted above.

Trade associations must never be used as a forum to agree a common approach to a customer or

devise an ‘industry solution’ to a commercial issue such as pricing, discounts or promotions.

In gathering competitive information, always follow the Diageo Know the Competition

Guidelines and always comply with applicable laws. Do not seek or accept confidential

information from competitors. You must not use deception, misrepresentation, or inducement

to encourage customers, suppliers or former employees of competitors to provide information

that they should keep confidential.

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We must adhere to all laws intended to protect and promote free and fair competition around the world

You can get further advice and support regarding competition and anti-trust issues from your Legal team,

Procurement team or the Global Compliance & Ethics team.

The Diageo Competition & Anti-trust Guidelines contain further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confidential report using SpeakUp.

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CustomersMany countries prohibit any attempt to agree resale prices, fix a minimum price or incentivise

customers to follow pricing recommendations. In addition, certain countries prohibit or limit

a supplier from imposing conditions of sale that can exclude competitive products or limit

a customer’s scope of resale.

Diageo purchases goods and services from suppliers who may also be customers of the

business. This is normal business practice but we must never pressure suppliers to buy our

products in order to become or remain a supplier.

You must follow your local guidelines and the advice of your Legal and Procurement teams

to ensure you understand what practices are acceptable.

We are all expected to:• Familiarise ourselves with and always follow the Competition and Anti-trust Guidelines

for our particular market.

• Never talk with or share information, directly or indirectly, with competitors to fix prices or

other terms of sale, set production levels, divide up markets, customers or territories, or to

boycott any customer.

• Never discuss with competitors details of pricing, costs, profits, margins, trading terms,

marketing and distribution plans or new product launches.

• Always report to the Legal team any instance where a competitor has raised with you any

of the subjects described above, either formally or informally.

Competition & anti-trust (continued)

You can get further advice and support regarding competition and anti-trust issues from your line manager,

Legal team, Procurement team or the Global Compliance & Ethics team.

The Diageo Competition & Anti-trust Guidelines contain further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confidential report using SpeakUp.

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One of our customers has

asked if he can pay through

a mix of different accounts

using a combination of cash

and cheques. Is this okay?

You should be especially

careful with these sorts

of transactions as it could

indicate money laundering.

Remember that Diageo cannot

accept cash in excess of £5,000

(UK)/$10,000 (US) for any one

sales transaction or series of

related sales transactions, nor

can we accept third party

cheques. Inform your line

manager or Legal team before

responding to the customer.

We have a customer

we know well and have

been dealing with for many

years without any problem.

I recently asked them to

update their information but

it hasn’t been forthcoming.

Should I be concerned?

Yes. Although there

may be an innocent

explanation, you cannot be

certain. We need to keep

our customer data current

to avoid opening Diageo up

to involvement in any illegal

activity. Notify your Legal and

Finance teams if you are not

able to verify a customer’s data

at least once every six months.

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Money laundering is the criminal practice of filtering money which has come from illegal

activities through a series of transactions in order to ‘clean’ it and give it the appearance of

being from legitimate sources.

Each Diageo business unit must have ‘Know your Customer’ procedures to determine the

identity and legitimate operations of customers, and maintain procedures to prevent

acceptance of suspicious payments. This specifically includes payments with currency

in excess of £5,000 (UK)/$10,000 (US) for any one sales transaction or series of related sales

transactions, money orders, travellers cheques, or payments from accounts in the names

of third parties, i.e. from anyone other than the invoiced customer.

It is the responsibility of local management to ensure that Diageo conducts business in accordance

with all local legal requirements, including compliance with any currency reporting requirements.

The Legal team can give you further advice on our Anti-Money Laundering Policy.

Knowing your customer is a continual process and, as a minimum, customer data must be

reviewed every six months.

We all need to be vigilant of circumstances that may indicate improper transactions, for

example, a customer who is unwilling to provide personal or business background information

or a customer who wishes to pay with large amounts of cash or appears unconcerned with

price, or other terms and conditions of purchase.

We are all expected to:• Ensure we follow the ‘Know your Customer’ processes detailed in the Diageo Anti-Money

Laundering Policy.

• Bring to the attention of the Legal team any suspicious transaction that may contravene

Diageo’s Anti-Money Laundering Policy.

• Be alert to any changes in customer details, circumstances and profiles and notify these

to the Finance team.

• Conduct business in accordance with any local legal requirements, including any currency

reporting requirements.

Money laundering

We comply with money laundering prevention laws and do not condone, facilitate or support the laundering of ‘dirty money’

You can get further advice and support regarding anti-money laundering from your line manager, Legal team

or the Global Compliance & Ethics team.

The Diageo Anti-Money Laundering Policy contains further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

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I’ve been travelling a lot

with work recently and

I’ve lost some of my receipts.

I’ve heard of colleagues in the

same position adding a few

fictitious receipts of the same

value to make sure they don’t

end up out of pocket. I’m sure

this is okay, isn’t it?

No, it’s not okay. It means

that the expense reports

are inaccurate which ultimately

results in inaccurate accounts.

The fact that you are aware

of others acting in this way

does not make it acceptable.

You should talk to your line

manager to discuss a resolution

to your current situation and

also highlight your concern

that this may be common

practice. In future, take care

to ensure you keep your

receipts safe.

We are approaching

the end of our reporting

period and my line manager

has asked me to offer to pay a

couple of our customers to buy

product now rather than in the

next period. I don’t think it will

have any negative impact on

the customer to bring these

purchases forward. Is this okay?

No. Using aggressive

marketing to increase

sales in a period is okay but

practices that effectively

shift the next period’s sales

to the current period for the

purpose of meeting targets

is not acceptable. There may

be legitimate reasons for both

Diageo and our customers to

wish to increase levels of stock

outside of normal trade but

such activity must always

be driven by clear

commercial reasons.

We must ensure that any data, information or records which we create or for which we are

responsible are correct and accurate. Such information can take many forms, ranging from the

Diageo Annual Report to our personal travel and expense claims.

Honest, accurate and objective recording and reporting of information, financial and non-

financial, is required not only to meet legal and regulatory requirements but to fulfill our

responsibilities to our shareholders and the public and to enable us to make informed decisions

about our business.

We must comply with all laws and external accounting standards and ensure that the

information we supply to Diageo’s auditors, regulatory agencies, and government

bodies is accurate, complete and provides a true and fair view of the financially reported

period. All transactions and contracts must be properly authorised and accurately and

completely recorded.

Accurate reporting of Diageo’s financial information includes appropriate recognition of sales

and profit. Any activity aimed at artificially inflating or shifting sales or profit between reporting

periods may result in a misrepresentation of our position and is unacceptable.

We must ensure that we act with complete integrity in our travel and expense claim submissions.

Claims must be compliant with the relevant local policy, relate to legitimate business expense

and be accurate. Any falsification of expense claims will be treated extremely seriously.

We must never make a false or misleading entry into any report, record or expense claim.

Falsifying records and accounts or misrepresenting facts may constitute fraud and in addition

to disciplinary action, could result in civil and criminal penalties for the individual and Diageo.

We are all expected to:• Create and maintain complete and accurate accounts, data and records.

• Be vigilant in identifying and reporting any potential misrepresentation of Diageo accounts,

data or records or any incidence of potential fraud or deception.

• Demonstrate integrity and diligence in submitting our travel and expense claims

and in approving those of others.

• Ensure that any contractual commitments which we make on behalf of Diageo are within

the scope of our delegated authority.

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Accurate reporting & accounts

The financial and non-financial information we create and maintain must be true, complete and accurate

You can get further advice and support regarding accurate reporting & accounts from your line manager, Finance team or

the Global Compliance & Ethics team.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

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I found some documents

left in a meeting room

that contained the salary details

of my colleagues. I don’t want

to get anyone into trouble but

I think people need to be more

careful with information like

this. What should I do?

If it is clear where the

documents came from

you should return them as

soon as possible to the relevant

owner by confidential means

or, if not possible, to HR. You

also have a duty not to disclose

any confidential information you

may have inadvertently read.

It will be my colleague’s

50th birthday next week

and I’d like to send her a

surprise gift. I asked HR for her

home address as I wanted to

get it delivered rather than

carry it into work. I was told

that wasn’t possible due to

data privacy laws. Is this right?

Yes, it is. Diageo has an

obligation to protect the

privacy of all employees and

although it may be that your

colleague would have no

objection to you obtaining her

home address for this purpose,

the HR team cannot make this

judgement on her behalf and

as a result must decline

your request.

You can get further advice and support regarding data privacy from your line manager, Legal or IS teams or the

Global Compliance & Ethics team.

The Diageo Global Data Privacy Policy contains further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

• fairly and lawfully obtained and managed

• processed only for limited or stated

purposes

• accurate, relevant and not excessive

• not held for longer than is necessary

• processed in line with an individual’s rights

• securely stored

• not transferred to other countries without

adequate protection.

We are all expected to:• Only use personal data to which we have access for Diageo business related reasons

and ensure its use is fair and lawful.

• Ensure we comply with all applicable local data privacy laws and other requirements

referred to above in addition to the Diageo Global Data Privacy Policy.

• Ensure that individuals who provide personal data are made appropriately aware of who

will have access to the data and for what purpose.

• Refer to the Legal team all formal statutory or regulatory requests or complaints by

individuals to access personal information relating to them.

• Ensure that any copying or distribution of personal data (e.g. to third parties) is necessary.

Do not initiate significant data processing activities (such as direct marketing) without

considering data privacy implications.

• Make use of training materials and advice and participate in privacy compliance checks

as required from time to time.

Diageo holds personal data about employees, customers and suppliers, consumers and other

individuals, including prospective and former employees. In particular, this information is held

in email systems, HR and marketing databases. We must respect the confidential nature of any

personal data we gather and we have a responsibility to keep it secure.

Each Diageo business unit and third party that collects and processes personal data on

Diageo’s behalf must comply with our Global Data Privacy Policy and all other relevant policies,

guidelines, binding rules and procedures. In some countries, compliance with data privacy

regulations is required by law and any failure to do so can result in financial and criminal penalties

for the individual and Diageo. We may implement additional policies or guidelines in order

to satisfy local data privacy laws and regulations.

Personal data which we hold must only ever be used for Diageo business purposes and we

must ensure it is:

Data p

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Data privacy

We apply the highest standards in protecting the personal information that we collect in our business activities

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I’m organising a meeting

for our team at an out of

office venue and I’m currently

developing the agenda. I’ve

been told that I need to go

through the emergency

procedure information at the

beginning of the meeting.

It doesn’t sound like a very

exciting way to start. Is it

really necessary?

Yes, it is. We have a

responsibility to ensure

safe and secure working

conditions for all our

employees when on Diageo

business even if this business is

conducted outside of Diageo

premises. Spending a few

moments outlining the fire

and evacuation procedures for

the venue will help to protect

your colleagues should an

emergency occur.

I recently tripped on some

loose floor covering. I

didn’t hurt myself but someone

told me I should report it

anyway. However, I don’t want

to jeopardise our safety record.

What should I do?

You should always bring

to the attention of your

line manager, Occupational

Health & Safety Officer or

local Facilities team, any near

misses or hazards that could

have caused an accident. By so

doing, we can rectify problems

before they can cause serious

accidents and ensure a safe

working environment for all.

You can get further advice and support regarding health, safety and security from your line manager, Occupational

Health & Safety Offi cer or local Facilities team.

The Diageo Occupational Health & Safety Policy and Diageo Physical Security Policy contain further information

and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

We are all expected to adopt a proactive, co-operative attitude towards the health, safety

and security of Diageo employees, customers and suppliers, and others working at or visiting

Diageo property. It is our intention that everyone goes home safe, every day, everywhere.

All our operations must be conducted in compliance with applicable health and safety laws

and regulations, company standards and best practice in workplace health, safety and security.

We take all reasonable and practical steps to ensure that the premises where our employees

operate are secure and provide a zero harm working environment.

Each of us should be aware of applicable Diageo safety programmes and safety and health

regulations and be appropriately trained for our role, in order to conduct our activities in a safe,

healthy and responsible manner.

We will act to mitigate risks which arise from deliberate or accidental breaches in our physical

security or threats to our people.

We are committed to continual improvement in our Occupational Health & Safety Policy

management and performance and we monitor our progress against health and safety

objectives, targets and best practice to ensure this.

We are all expected to:• Follow the Diageo Occupational Health & Safety Policy and Diageo Physical Security Policy,

as applied to our location and type of work.

• Challenge unsafe behaviours of others in a timely manner to demonstrate that unsafe

behaviours are unacceptable.

• Promptly report accidents, incidents, near misses, non-compliance with regulations or

anything else posing a risk to health, safety and security.

• Understand the hazards associated with our own job and those associated with our

colleagues’ jobs. Manage the risks responsibly and ensure any required health and safety

training has been completed.

• Integrate health, safety and security considerations into our day-to-day working activities.

• Make sure we know what to do if an emergency occurs at our place of work.

Health, safety & security

Each of us should behave in a manner that promotes a positive safety culture and openly challenge unsafe behaviour

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I’ve been asked to

undertake interviews

for a role within my team. In

my mind I’m clear that the

job could not be done by a

young female as it involves

travel to countries where the

environment is challenging.

However, two of the candidates

are young females. Should

I turn them down without

interview?

By doing so you would

be not only breaching

Diageo’s Global Resourcing

Policy but potentially also

breaking the law. If the young

female candidates have the

ability and are qualified to

perform the role, you must

not discriminate against them

and should interview them

and consider them for the role

without regard to their age

or gender.

My line manager can

be very intimidating and

sometimes even personally

insulting to people in my team.

I know he has high standards

and wants us to perform well

but it is impacting the morale

of the team and a couple of

people are talking about leaving.

I’m worried that if I report it, I

might just make the situation

worse. What should I do?

Behaving in a bullying

and intimidating way

is unacceptable, regardless

of the circumstances or an

individual’s position within the

organisation. You should raise

the matter with your team’s HR

contact, the Global Compliance

& Ethics team or you can use

SpeakUp to make a report.

Diageo will not tolerate any

reprisal against an individual

for raising an issue or making

a report in such situations.

You can get further advice and support regarding discrimination or harassment issues from your line manager,

HR team or the Global Compliance & Ethics team.

The Diageo Global Resourcing Policy and the Diageo Human Rights Policy contain further information

and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

As Diageo employees we all have the right to expect that our dignity and human rights will be

respected and that we will be treated fairly in carrying out our work.

In all aspects of employment, we will treat individuals justly, solely according to their abilities

to meet the requirements and standards of their job. We must do so without regard to factors

such as race, religion, colour, ethnic or national origin, disability, sexual orientation, gender, age

or marital status. We will make reasonable job-related accommodation for any employee with

a disability when notified that this is required.

We will not tolerate employees being subjected to physical, sexual, racial, psychological, verbal,

or any other form of harassment or abuse. Diageo will ensure procedures are in place to detect

failures to live up to this standard and to deal with them swiftly and effectively.

We recognise the diverse skills and contributions of our workforce and will ensure that

individuals are justly and fairly remunerated for their contributions to the company.

We acknowledge and promote a healthy balance between employees’ working and home life

and respect the commitments they have outside of the work environment.

We are all expected to:• Ensure we do not discriminate against any individual or group based on factors which

are irrelevant to their ability to do their job.

• Never engage in any form of harassment or abuse, or any behaviour that could be viewed

as offensive, intimidating, malicious or insulting.

• Support and promote Diageo’s commitment to diversity, individual contribution and

a fair and harassment-free workplace.

• Ensure that consumers, suppliers and other business partners are aware of Diageo’s

commitment to diversity and equal opportunity.

Discrimination & harassment

We value diversity and are committed to a respectful and fair working environment for all

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We recently went away

as a team and stayed at

a hotel. After dinner in the bar

one of my colleagues drank too

much and started behaving

rudely towards the hotel staff.

I was embarrassed as were

others who were with me. Her

line manager had left earlier

and so didn’t witness the

incident. Should I just

keep quiet about it?

No, you should not. As

employees of Diageo

we have a duty to be role

models for the responsible

use of alcohol. Inappropriate

behaviour of this kind could be

highly damaging to Diageo’s

reputation and is treated

extremely seriously. You should

report the matter to your

line manager or HR team, or

alternatively contact SpeakUp.

One of my colleagues is

regularly calling in sick,

disappearing and is making

mistakes in his work. He insists

everything is fine but I have

reason to suspect he may have

an alcohol problem. I want to

help but am worried that it’s

none of my business. What

should I do?

Such situations can be

uncomfortable and it

often feels easier to ignore

the situation and hope it

improves. However, this is

probably not in the best

interest of the individual or

Diageo. Discuss your concerns

with your line manager if you

feel comfortable doing so or

contact SpeakUp.

You can get further advice and support regarding responsible drinking from your line manager, Corporate

Relations team or the Global Compliance & Ethics team.

The Diageo Employee Alcohol Policy contains further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

Celebrating life, every day, everywhere, is at the heart of Diageo. We believe that our brands

can play a positive role in society when enjoyed responsibly and Diageo is at the forefront

of industry efforts to promote responsible drinking. Our approach is based on the following

key principles:

• to set world-class standards for responsible marketing and innovation

• to combat alcohol misuse, working with others on initiatives to reduce alcohol-related harm

• to seek to promote a shared understanding of what it means to drink responsibly.

We collaborate with other leading drinks companies and industry-funded organisations

around the world to help remind consumers to drink responsibly at all times.

We are committed to ensuring that as employees we understand the nature and effects of

alcohol. We are ambassadors for our brands and can enhance Diageo’s reputation by showing

a responsible attitude to drinking. In contrast, if we drink irresponsibly or commit offences

related to the misuse of alcohol, we put Diageo’s reputation at risk.

We have a global programme for all employees on the enjoyment and responsibility of

drinking, which is called DRINKiQ. DRINKiQ.com is Diageo’s global resource to help combat

alcohol misuse and promote information on responsible drinking through the sharing of best

practice tools, information and initiatives. These two initiatives are part of Diageo’s intention to

raise our collective drink intelligence.

The Diageo Employee Alcohol Policy defines appropriate behaviour and covers topics such

as alcohol and the workplace, drinking and driving, enforcement and problem drinking.

We are all expected to:• Behave in a way that enhances our corporate reputation. We are proud of our products

and of the way we carry out our business. We need to be mindful of this reputation and

show a responsible attitude to drinking.

• Ensure that our performance at work and judgement are never impaired by alcohol.

• Always obey the drink-drive legislation in our market and never put ourselves or others

at risk by drinking and driving.

• Seek medical advice or counselling from an occupational health centre or from an external

agency, if dealing with an alcohol related problem.

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I was recently on holiday

and saw in a local shop

a product which looked so

similar to a Diageo one that I

initially mistook it for being our

brand. I think people who don’t

know our brands as well as me

could be confused. Should I do

anything about it?

Yes, protecting our brands

is critical to maintaining

our reputation and the

goodwill of our customers. If

possible, you should buy the

product and pass this and

other relevant details to the

Legal team immediately on

your return. However, you

should not compromise your

safety and security in any way

and should never identify

yourself as a Diageo employee

in such a situation.

A couple of my friends

had one of our products

in a bar recently and both

thought it didn’t taste right.

Should I report this?

Yes, you should report

the matter through

Operation Copycat or

contact the Legal team or

Global Corporate Security

team directly so that they

can investigate further.

Infringements of our products

can take many forms and it is

possible that the product may

have been tampered with or

could have been a counterfeit.

We have an obligation to

protect both our consumers

and our brands.

You can get further advice and support regarding brand protection from your line manager, the Legal team

or the Global Compliance & Ethics team.

The Operation Copycat intranet site contains further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

Intellectual property laws protect Diageo’s valuable assets – our trademarks, copyrights,

patents, trade secrets, domain names, and related rights. These assets assure our consumers

that the Diageo products they buy are genuine.

Trademark and related laws protect our brands. Copyrights protect our communications,

unique advertising messages and designs. Our trade secrets, such as recipes, distilling

processes, price lists and customer lists, enable us to offer consumers unique products and

provide a competitive advantage in the marketplace. Our patents protect our inventions, such

as our unique technologies and production methods.

Infringing products are products that lead consumers to mistakenly confuse them with, or

falsely link them to, Diageo products. These can range from similarly named and/or designed

alcoholic beverages, to unrelated products using similar names, logos, packaging shapes,

trade dress, colours or designs. Counterfeit products are products that claim, falsely, to be

one of our products. They often re-use (refill) or copy our packaging. The contents of these

products are often inferior and can sometimes even be dangerous.

We all need to be alert to and report any suspected counterfeit or product infringements

promptly so that we can take action and limit any potential negative impact on Diageo.

The Operation Copycat intranet site provides further information on reporting suspected

counterfeit or product infringements.

If you are involved in developing products, advertising or promotion campaigns you should

contact the Legal team before any details are published or any samples or products are shown

to the public or to suppliers.

As we expect our intellectual property rights to be respected, we must respect the intellectual

property of other organisations.

We are all expected to:• Report any potential infringements through the Operation Copycat intranet site

or directly to the Legal team.

• Always consult the Legal team regarding securing Diageo’s rights when working

with suppliers to create intellectual property on our behalf.

• Ensure we do not use any names, designs or other materials that a consumer might

associate with another organisation or their brands without first seeking the advice

of the Legal team and obtaining permission if required.

• Never download, copy, distribute, post on a website or use any materials covered by

another person’s or organisation’s copyright without obtaining permission.

Brand protection

We must protect Diageo’s brands and intellectual property rights and avoid infringing the rights of others

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I’ve recently started

working for Diageo.

My uncle works in the same

industry and is keen to talk

about the differences and

similarities between our two

companies. I’m excited about

working for the company and

want to talk about it but how

much can I say?

You should be cautious

even with a close member

of your family. We want you

to talk about Diageo and

be an ambassador for the

company but you can do that

without revealing confidential

information. Ask yourself

whether the information you

are sharing is available to the

general public through the

media, our websites or our

marketing and promotional

information. If not, you should

not discuss it with anyone

outside of Diageo.

I’ve just joined Diageo

from a competitor

and brought with me lots

of information which I think

would be useful to the

company. Given that it relates

to work with which I was

involved personally, is it okay

to share it with my new team?

Not if the information

is of a confidential nature.

Even after you have left the

company the information

remains confidential if it is not

publicly available. You have

been hired on the basis of your

experience and expertise not

for the confidential information

to which you have access.

You can get further advice and support regarding the treatment of confi dential information from your line manager,

the Legal team, the Global IS team or the Global Compliance & Ethics team.

The Diageo Global Information Security Policy contains further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

Many of us have access to confidential information through the work we do. This could

include business plans, financial data, details of innovation, marketing or sales programmes,

new products, merger or acquisition activity, senior management changes or a range

of other information.

We should never share Diageo’s confidential information with non-Diageo employees, unless

those third parties are bound by confidentiality obligations. This applies even if we leave

Diageo and for as long as the information is not generally available to the public. Internally,

we should consider carefully with whom we share confidential information, restricting it to

those that need to know in order to carry out their work. In this way we can avoid inadvertent

disclosures outside the company.

Diageo classifies its information in accordance with the information’s sensitivity and value. The

four classifications of information are Diageo Public, Diageo Internal, Diageo Confidential and

Diageo Top Secret. All information that is not in the public domain must be labelled as Diageo

Internal, Diageo Confidential or Diageo Top Secret.

We must also respect the confidential information of others. We should never seek to obtain

or disclose the confidential information of other companies, whether it comes to us directly

or from third parties.

We are all expected to:• Never discuss confidential information with non-Diageo employees, unless those third

parties are bound by confidentiality obligations.

• Be mindful of the unintentional disclosure of confidential information through conversation

or the use of documents in public places.

• Notify the Legal team immediately if we become the recipient of the confidential

information of another company.

• Never accept, solicit or divulge confidential information from or about any third party,

including customers.

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Proper protection of our confidential information is vital to protecting Diageo’s brands, reputation and business

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I am going on holiday

and someone will

temporarily cover my role.

As it is only for two weeks it

doesn’t seem worth getting

her a network user ID and

password as she can just use

mine. Is this okay?

No, you should never

share your user name

and password even if it seems

that this would be the most

efficient thing to do. Not

only does it breach Diageo

policy, but it potentially puts

you at risk if someone acts

inappropriately while using

your username and password.

Plan ahead and ask your IS

team to create a new user

name for the individual before

you go on holiday.

I am going to be travelling

a lot over the next few

weeks and don’t really want

to have to take my laptop. I

know I’ll be able to get access

to my personal email over

the internet so can I just set

up a rule in my Diageo inbox

to forward all my email to my

personal address?

No, you should not

forward Diageo emails to

a personal address when you

do not know the content. Emails

could contain confidential

information normally protected

by the Diageo digital security

systems, which would not be

the case with your personal

email account.

You can get further advice and support regarding information systems usage and security issues from your line

manager, the Global IS team or the Global Compliance & Ethics team.

The Diageo Global Information Security Policy contains further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

Information security

We must be diligent in protecting the security of Diageo’s information systems and the information stored on them

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Lack of diligence by an individual can lead to a breach of our information security affecting

the whole company. Everyone who uses the Diageo digital systems – employees, contractors,

consultants and other people with temporary access – must ensure that these resources are

used appropriately and in line with our Global Information Security Policy.

Diageo’s digital resources, including systems, software, office equipment, telephone and email

services are intended to be used for conducting Diageo’s business. Incidental or occasional

personal use of such assets is acceptable so long as it does not interfere with you performing

your job.

However, you should not expect privacy if you conduct personal business using company

resources. Diageo may monitor the use of its telephones, computers and email systems and

see the information that you create or exchange with others.

We must all follow the guidance provided in the Global Information Security Policy related

to computer usage, password and access codes, security measures and information handling.

We are all expected to:• Never share our username or password.

• Ensure we do not access, download, create or forward email, documents or images

that may cause offence or distress to other persons.

• Ensure we do not install or use, hardware or software on any Diageo system that has

not been specifically approved by the IS team.

• Ensure we do not send confidential information to a non-Diageo email system without

additional protection as specified in the Global Information Security Policy.

• Always save important data on the network based drives for reasons of data security

and data recovery.

• Ensure that all our personal data maintained in Diageo’s systems, such as the Global

Directory and Diageo One is current and accurate.

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My email inbox is full and

I can’t send or receive

any more mail. I don’t have

the time to go through each

email and I’ve got documents

I need to send urgently. I’ve

decided to delete all the emails

with attachments as these are

taking up the most space. This

is the best solution, isn’t it?

No, you need to review

what you retain and what

you delete against the records

retention schedule relevant for

you. In future, try and manage

your email more effectively.

File documents as you receive

them and regularly review what

can safely be deleted based on

your retention schedule.

I’ve inherited documents

and emails from my

predecessor which could have

been destroyed as their normal

retention period has expired.

Now I’ve heard there might

be a legal case and I’m not

sure they’d be helpful so I’m

thinking of destroying them

before it starts. Is this okay?

No, it is not. Whether

or not the legal case

has started or you have been

contacted by our lawyers, you

must preserve information

that could be relevant, even if

in normal circumstances, you

could have destroyed it, in

accordance with our policies.

In this situation, destroying or

altering records can have very

serious consequences. Consult

the Legal team for further advice.

You can get further advice and support regarding records management from your line manager, Legal team,

the Records & Information Management Compliance team (contact hp.records@diageo.com) or the

Global Compliance & Ethics team.

The Diageo Global Records Retention Policy, individual business units’ policies and the Diageo Communication

and Document Production Guidelines contain further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

Records management

Our records must be correctly managed to satisfy legal and regulatory requirements and protect Diageo’s interests

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Our records contain valuable information for use by the business and to provide evidence of

our actions, decisions and obligations. Records can be documents and data in many formats

and media, including paper, film and electronic, and may be held within IT systems and

computers as well as in offices and stores. We must ensure that the records for which we are

responsible are correctly managed, from creation to disposal, including those held for us by

third parties.

Whenever we create, collaborate on or communicate data and records we must exercise care,

and follow the Diageo Communication and Document Production Guidelines and appropriate

confidentiality, privacy and security requirements.

We are required by laws, regulations and business requirements to retain records for certain

periods of time depending on their nature. The Diageo Global Records Retention Policy and

individual policies, procedures and schedules applicable to each business unit explain the

legal and business requirements relating to the retention of our records.

It is very important that records (including email) relating to pending litigation or a regulatory

investigation are not destroyed, even if they would be normally. Our Legal and Tax teams will

notify relevant employees when this happens and their instructions must be followed carefully.

We are all expected to:• Ensure that we maintain complete and accurate records for the business activities for

which we are responsible.

• Understand and follow the Records Retention Policy, procedures and schedules relevant to

our records, including the Diageo Communication and Document Production Guidelines.

• File records correctly (both paper and electronic), transfer them to storage if and when

appropriate, and review them regularly to identify those due for disposal in

accordance with policy.

• Comply fully and immediately with any legal requirement to suspend normal disposal of

records (and other information sources) because of litigation or a regulatory investigation.

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I have just received

an invite to speak at an

industry conference. I think it

would be a great marketing

opportunity for Diageo. I’d like

to accept. Do I need to check

with anyone first?

Yes, you should discuss

the invitation with your

line manager and Corporate

Relations team before accepting.

You should always be careful to

seek the appropriate approvals

when you are representing

or seen to be acting as a

spokesperson for Diageo.

I read an article in a

newspaper the other day

which stated certain things

about Diageo‘s business that

I know are wrong. Should I

contact the newspaper to

correct them?

No. You should always

be alert to reporting

about the company which is

incorrect or misleading, but it is

not your responsibility to seek

to correct such inaccuracies.

You should raise the matter

with your line manager or

contact the Corporate

Relations team directly.

You can get further advice and support regarding external communications from your line manager, Corporate

Relations and Investor Relations teams or the Global Compliance & Ethics team.

The Diageo Global Communications and Media Guidelines contain further information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

Everything we do, everything we say, and everything our key stakeholders say about us defines

Diageo’s business reputation. Our stakeholders are identified as our employees, investors,

consumers, the media, our communities, government and commercial partners – including

suppliers and customers.

Each of us has regular contact with one or more of these stakeholder groups in undertaking

our daily work. However, it is important that in doing so the Diageo Communications and

Media Guidelines are followed and the advice of the Corporate Relations team or the Investor

Relations team is sought where appropriate.

Management of Diageo’s day-to-day relations with the media are managed by the Corporate

Relations team – globally and in the markets – which owns and manages contacts with

government, media, employee and community stakeholders. Investor interaction is managed

by the Investor Relations team. We must direct all media and investor enquiries to these teams.

The Diageo Global Communications and Media Guidelines provide further information on our

approach to managing communications with our stakeholders.

We are all expected to:• Refer all media enquiries to the appropriate authorised person or Corporate Relations team.

• Avoid speaking to the media unless specifically authorised to do so.

• Avoid acting as a spokesperson for Diageo, its people, brands or performance, without first

consulting a member of the Corporate Relations team.

• Ensure all media announcements and press releases are approved in advance by an

appropriate member of the Corporate Relations team.

• Refer any approach by an investor or financial analyst to the Investor Relations team.

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It is crucial that our communications with stakeholders are managed according to Diageo communications and media guidelines

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A former colleague is

standing as a candidate

for local government and is

having a fundraising dinner.

He’s asked if some of my

colleagues and I would like

to take a table at the event.

Is this okay?

Diageo respects the

right of its employees to

personally support political or

charitable activities as long as

this activity is not associated

with Diageo. You are at liberty

to attend the dinner in a

personal capacity. However,

if a group of employees

attend the event it could be

misinterpreted that Diageo is

supporting the candidate and

so it would be best to avoid

such a situation.

I’ve been contacted by a

government committee

and asked to attend a hearing

as an expert witness. What

should I do?

You should notify your

line manager and contact

the Corporate Relations team

promptly who will advise you

how to respond. If you do

attend, the Corporate Relations

and Legal teams will support

you in preparing for the hearing.

You can get further advice and support regarding political activity from your line manager, Corporate Relations team

or the Global Compliance & Ethics team.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

As part of doing business, Diageo engages with governments, public interest groups, industry

associations and a broad range of other similar bodies around the world. In doing so, we must

ensure we comply with all laws governing political activity.

We must not engage in lobbying or have contact with legislators, political candidates,

regulators, government employees or public-interest groups without the direction of the

Corporate Relations team and where appropriate the Legal team.

None of us should make payments on Diageo’s behalf to political candidates or parties or

to support political activities, except in very special circumstances and with the prior approval

of the Global Corporate Relations Director and the Global Compliance & Ethics Director. Always

seek guidance from the Corporate Relations team.

Diageo recognises each employee’s right to participate as an individual in political activities.

However, these activities must be kept separate from the workplace. Diageo funds or resources

must not be used to support such activities without the prior approval of the Global Corporate

Relations Director and the Global Compliance & Ethics Director.

In particular, Diageo disassociates itself from any political or religious activity that incites

extremism or undermines our commitment to cultural diversity and equal opportunity.

We are all expected to:• Talk to the Corporate Relations team or Legal team before engaging in contact with

government, regulators, legislators or lobby groups on Diageo’s behalf.

• Never make payments to political parties or candidates on Diageo’s behalf without prior

approval from the Global Corporate Relations Director and the Global Compliance

& Ethics Director.

• Keep personal political activities separate from work activities and do not use company

time or resources to support them.

• Consider if any personal political activity could be open to the misinterpretation that

it is undertaken on Diageo’s behalf.

Political activity

We should not engage in contact with government orpolitical organisations or individuals on Diageo’s behalf without approval

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A customer has asked if

Diageo would be prepared

to offer some office space

to host an event they are

organising for a charity as their

premises are not sufficiently

large. Can I agree?

You should speak to

your line manager and

business unit head before

making any commitment.

Diageo encourages the

support of community and

charitable activities but it is

important to ensure alignment

with Diageo criteria particularly

given that the request has

come via a customer.

I’m involved with a

programme to support

local schools in helping children

to improve their reading. They

are currently looking for new

volunteers and I am thinking of

asking my colleagues whether

they would like to get involved.

Is this okay?

We want to encourage

employees to pursue

issues which are important to

them and their communities.

In everything we do we must

take care that our actions

are not misinterpreted as

an attempt to market our

products to those under legal

purchase age. If you are in any

doubt consult your local

Corporate Relations Director.

You can get further advice and support regarding community & charitable activity from your line manager,

Corporate Citizenship team, local Corporate Relations team or Global Compliance & Ethics team.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

Diageo’s business activities directly affect the lives of millions of people around the world.

This brings a responsibility to ensure that all those with a stake in Diageo can benefit from

the relationship. Being socially responsible and investing in our communities is at the heart

of being ‘proud of what we do’.

Inherent in our Code is the belief that countries and communities in which we operate should

benefit from our presence. We believe that by being active and caring about the communities

where we operate we can best meet our social responsibilities and bring about positive change.

Diageo is committed to investing in community programmes. However, we should not make

charitable or community contributions on Diageo’s behalf without the approval of the Global

Corporate Relations Director. Appropriate criteria must be used to select the charity and

decide the amount of the donation. In addition, care must be taken to ensure compliance

with accounting and tax requirements.

The Diageo Corporate Citizenship team provide expertise and support to our business units

on Diageo’s community investment programme, including focus areas and funding criteria.

While financial contributions are important, active involvement can often achieve much more

in our communities, whether through the time and skills of our people or supplying surplus

products and other ‘in-kind’ resources.

We encourage the involvement of all employees in community initiatives because it not

only benefits each project but also fosters team spirit and enhances individuals’ capabilities

and experience.

We are all expected to:• Reflect Diageo’s care for and commitment to the communities in which we operate in

undertaking our work.

• Seek the prior approval of the Global Corporate Relations Director before making

charitable contributions on Diageo’s behalf.

• Take particular care when considering making charitable or community donations

at the request of customers or business partners.

Community & charitable activity

We are committed to playing an active and positive role in our communities and we encourage employees to do the same

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I heard informally that

one of our suppliers is

under investigation for using

forced labour. We haven’t heard

this from the supplier and I’m

not aware of any previous

problems. Should I ignore

the rumours?

No, Diageo will investigate

the matter further even

though the rumours may turn

out to be wrong. Talk to your

line manager, Procurement

team, Global Compliance &

Ethics team or Legal team

who will advise on the

appropriate action.

We are considering

working with a supplier

but we are concerned that

the wages they pay to their

employees, are below the

normal level for the industry.

The supplier has agreed to

address this if they are awarded

the contract. Given this

commitment, is it okay to

go ahead?

Diageo expects its

suppliers to pay fair

wages in line with the norms

for the industry and market

and not to require anyone

to work excessive hours,

particularly where this might

impact personal health or

safety. You should raise the

issue with your line manager

and seek guidance from

the Procurement team or

Corporate Citizenship team on

the appropriate action to take.

You can get further advice and support regarding human rights issues from your line manager, Procurement team,

the Corporate Citizenship team, local Corporate Relations team or Global Compliance & Ethics team.

The Diageo Human Rights Policy and Diageo standards on Partnering with Suppliers contain further information

and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

Diageo recognises its responsibility under the Universal Declaration of Human Rights to use

our influence to promote and protect human rights and to ensure that our business operations

do not contribute directly or indirectly to human rights abuses.

The Diageo Human Rights Policy sets out the principles and standards we apply to our

employees, consumers of our products and the communities within which we operate. We also

recognise international labour standards as set out in the International Labour Organization’s

(ILO) conventions and recommendations.

We seek to establish and adhere to clear ethical standards for ourselves and expect similar

standards in all third parties who act with us or on our behalf. In particular, we expect our

suppliers to meet all applicable legislation and ratified ILO conventions and recommendations,

and the requirements set out in the Diageo standards on Partnering with Suppliers.

Diageo does not make use of forced or compulsory labour. We will employ people under

the age of 18 only in compliance with local law and UN Global Compact guidelines. For any

Diageo employee under the age of 18, we will pay particular attention to their vocational

training and development needs.

We respect the right of employees to join or not to join trade unions, and generally to join

together for the purpose of promoting common goals.

We are all expected to:• Always respect the human rights of those with whom we work and come into contact

as Diageo employees.

• Encourage partners, suppliers and other third parties to adopt similar standards with

respect to human rights.

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We have a responsibility to promote and protect human rights and freedoms in everything we do

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I am passionate about

environmental issues and

I question why we don’t do

more to reuse and refill bottles

in the market in which I work.

Why is this?

Diageo recognises that

waste occurs when

consumers dispose of our

bottles, cans and other

containers. Our marketing

teams and agencies follow

guidelines intended to

balance the functionality of

our packaging with a need to

minimise its environmental

impact. Refillable glass bottles

may be environmentally the

best solution in some cases,

for example, for beer which

is consumed near where it

is brewed. However, they

may not be economically

sustainable for spirits shipped

between countries or at risk

from counterfeiters.

My business unit has

instigated an initiative

to encourage us to only print

documents when necessary. I

prefer to look at things in hard

copy rather than on the screen

so won’t be following this

approach. Is this okay?

Diageo respects the

environment and seeks

through a range of initiatives

to minimise its environmental

impact. Reducing our usage

and waste of materials is one

of the ways of doing this.

Although you may prefer to

operate in a certain way, we all

have a responsibility to try to

change our behaviours where

required to support Diageo’s

environmental strategy.

You can get further advice and support regarding environmental matters from your line manager,

Corporate Citizenship team, local Corporate Relations team or Global Compliance & Ethics team.

The Diageo Environmental Policy and Diageo standards on Partnering with Suppliers contain further

information and guidance on this subject.

Don’t forget, you can always discuss concerns or make a confi dential report using SpeakUp.

We aim to achieve continuous improvement in environmental performance, concentrating our

efforts on areas of greatest impact at our manufacturing, distribution and large office sites.

We seek to comply with the spirit as well as the letter of applicable environmental laws and

regulations with regards to the environment. Where none exist, we set ourselves appropriately

high standards.

Throughout our operations, we will consider the environmental implications of every major

business decision that we make. In doing so, we seek to support environmental sustainability

and biodiversity.

We are committed to driving down the environmental impact of our operations through the

efficient use of resources, transport planning, the reduction of waste and emissions and the

careful handling of hazardous substances.

We will educate and motivate our employees to conduct activities in an environmentally

responsible manner and we encourage our business partners, suppliers and contractors to

do the same.

We engage our key stakeholders, including employees and communities, in dialogue on our

environmental programmes and monitor our performance against best practice to ensure

continuous improvement.

Our environmental standards apply to all locations and aspects of our business.

We are all expected to:• Demonstrate a commitment to the environmental standards as outlined in the Diageo

Environmental Policy and the Diageo Annual Corporate Citizenship Report.

• Support local environmental sustainability initiatives such as energy saving

or waste reduction programmes and challenge unsustainable activities if they occur.

• Work with our suppliers to develop appropriate environmental management systems

which reflect Diageo’s commitment to reducing the environmental impact of the supply

chains of which we are a part.

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We are committed to operating in an environmentally responsible way to protect and enhance our people, brands and the communities in which we work and live

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Contacts & links

Co

ntacts &

links

Guidance is given throughout the Code as to who you can ask for further information or advice

on a particular subject. On all matters you can go to your line manager to ask for help or raise

an issue.

You can contact the Global Compliance & Ethics team to ask for advice on who to speak

to regarding a particular issue. You can also report to the team matters about which you

are concerned.

Global Compliance & Ethics team8 Henrietta Place

London W1G ONB

United Kingdom

Tel: +44 (0) 20 7927 5200

Email: global.compliance.programme@diageo.com

The Code & Diageo policiesThe Code of Business Conduct is available in the following languages, copies of which

can be downloaded from the Diageo intranet or are available from the Global Compliance

& Ethics team:

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• French

• Spanish

• Italian

• Portuguese

• Hungarian

• Polish

• Dutch

• German

• Russian

• Greek

• Turkish

• Thai

• Japanese

• Chinese (Traditional)

• Chinese (Simplified)

• Korean

• Vietnamese

All the policies referred to in the Code and other Diageo policies and guidelines, which may

be relevant to your job, can be found on the Diageo intranet.

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SpeakUp

Global number: +44 (0)1249 661792

Email: diageospeakup@expolink.co.uk

Internet: www.expolink.co.uk/whistleblowing-hotline/for-employees.htm

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If there is not a freephone

number listed for your

country, please use the

reverse charges global

number provided at the

top of this page.

Local freephone numbers:

Argentina: 0800 666 2603

Australia: 1800 121 889

Austria: 0800 281700

Belgium: 0800 71025

Brazil: 0800 891 8807

Bulgaria: 008001104474

Canada: 1888 268 5816

Chile: 12300200412

China: 00 800 3838 3000

Colombia: 01800 944 4796

Croatia: 0800 222 845

Cyprus: 800 95207

Czech Republic: 800 142428

Denmark: 8088 4368

Eire: 1800 567 014

Egypt: 0800 000 00 23

Estonia: 8000044265

Finland: 0800 116773

France: 0800 900 240

Germany: 0800 182 3246

Greece: 00800 441 31422

Hawaii: 1866 293 2604

Hong Kong: 800 930770

Hungary: 06800 14863

Iceland: 8008279

India: 000 8004401286

Indonesia: 001 803 0441 1201

Israel: 180 944 6487

Italy: 800 783776

Japan: 00531 78 0023

Korea (South): 00308 442074

Latvia: 80002670

Lithuania: 880030444

Luxembourg: 8002 4450

Malaysia: 1800 807055

Malta: 800 62404

Mexico: 01800 123 0193

Netherlands: 0800 022 9026

New Zealand: 0800 443 816

Norway: 800 14870

Philippines: 1800 1442 0076

Poland: 00800 441 2392

Portugal: 800 880 374

Puerto Rico: 1866 293 1804

Romania: 08008 94440

Russia: 10 800 2058 2044

(restricted coverage)

Singapore: 800 4411 140

Slovakia: 0800 004461

Slovenia: 0800 80886

South Africa: 0800 990520

Spain: 900 944401

Sri Lanka: 011 244 5413

(omit 011 if dialling from Colombo)

Sweden: 0200 285415

Switzerland: 0800 563823

0800 563012

Taiwan: 0080 104 4202

Thailand: 001 800 442 078

Turkey: 00800 4463 2066

UK: 0800 374199

United Arab Emirates: 80004413873

USA: 1877 533 5310

Venezuela: 0800 100 3199

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Diageo plc

8 Henrietta Place

London W1G 0NB

United Kingdom

Tel +44 (0) 20 7927 5200

Tel +44 (0) 20 7927 4600

www.diageo.com

Registered in England

No. 23307