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What do we mean by Speaking Up?

Speaking up is sharing a concern about suspected misconduct within our Company, that is: any violation of laws and regulations, our Code of Business Conduct and/or the various policies, rules, standards and procedures under which our Company operates.

Which channels can I use to Speak Up?

Our Speak Up procedure is flexible and allows you to raise concerns about suspected misconduct through a variety of channels. As a general guideline, the first person to approach when raising a concern is your line manager or supervisor. In addition, our Company has appointed Trusted Representatives. Please refer to your Company’s Speak Up procedure for their contact details. You can also contact our Company’s Business Conduct Office in Amsterdam, by e-mail businessconduct@heineken.com or P.O. Box 28, 1000 AA Amsterdam, The Netherlands or use our external Speak Up Service Provider, EthicsPoint, online or by phone.

Am I protected from retaliation?

Yes, Speaking Up is encouraged and employees who Speak Up are protected. Reporting suspected misconduct in good faith will not lead to any negative action against you (such as demotion, suspension, loss of benefits or harassment). Our Company does not tolerate any form of threat or retaliation against a person for raising a concern in good faith. This protection also extends to anyone giving information or cooperating in a follow-up investigation.

May I report my concern anonymously?

You can report suspected misconduct anonymously (where allowed by the laws of your country). Please keep in mind, however, that it is usually more difficult, and in some circumstances even impossible, for us to thoroughly deal with reports that are made anonymously. Therefore, where you are comfortable, you are encouraged to share your identity with us when filling a report. Our Company will do everything within reason to keep your identity confidential.

Will my identity and report remain confidential?

All reporting is done in confidence, unless you allow our Company to disclose your identity. If you have asked our Company not to disclose your identity, we will not do so. The only exception is if we are required to do so by law or if an important public interest is at stake.

How do I follow up on my report via the Speak Up Service Provider?

After you complete your report (online or by phone), you will receive a unique code called a report key. You will also be asked to choose a password. You can use this key and password to call back or access the website (http://call.heiway.com) to check on your report. You can see whether people dealing with your report have feedback for you or further questions. You can also provide further information.

What can you expect if you Speak Up?

Our Company takes all reports of possible misconduct seriously. We will act on any legitimate formal report filed anywhere in the world. The report will undergo an initial review, and if necessary, it will be appropriately investigated. All investigations will be conducted carefully, confidentially and professionally. If it is determined that misconduct actually took place, our Company will take appropriate action.

When can I expect my concern to be dealt with?

If you submit a formal report, you will receive confirmation of receipt within 5 to 7 business days with an estimate of how long it will take to handle and investigate your concern. On average, closure of the matter can be expected within 2 to 3 months.

What is the role of EthicsPoint?

EthicsPoint is the external service company receiving your concern. EthicsPoint is an independent professional company that provides a secure and confidential telephone and web based service for those who wish to raise a concern.

What if it is an emergency?

The Speak Up service via EthicsPoint cannot be used for events presenting an immediate threat to life and property. Reports submitted through this service may not receive an immediate response. Please contact your local authorities if you require emergency assistance.

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