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The Carlsberg Group operates in a diverse, global marketplace and is constantly striving to be a responsible business partner and employer. The ambition of the Carlsberg Group is to be the fastest growing global brewer through fair operational practices in a sound, transparent and competitive business environment. This ambition has been translated into a set of principles, laid down in the Carlsberg Group Business Ethics Policy (“Policy”). The Policy contains specific rules of conduct for Carlsberg Group employ-ees to ensure ethical business conduct and compliance with all relevant laws and regulations throughout the Carlsberg Group.

The policy addresses 8 key topics:

1. Bribery

2. Facilitation Payments

3. Gifts, meals and entertainment

4. Donations

5. Conflicts of interest

6. Confidential information

7. Competition law

8. Fraud

CONTENTS

1.0 Bribery2.0 Facilitation Payments3.0 Gifts, meals and entertainment 4.0 Donations5.0 Conflicts of interest6.0 Confidential information7.0 Competition law8.0 Fraud

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YIn the Carlsberg Group, we believe in fair and transparent business practices. Our Business Ethics Policy and Guidelines seek to ensure ethical business conduct by guiding our employees when they face dilemmas of a business ethics nature in their day-to-day tasks.

Jørgen Buhl RasmussenPresident & CEO

Anne-Marie SkovSenior Vice-President Group Corporate Affairs

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BRIBERY

1.1 The Carlsberg Group and its employees shall not accept or offer bribes in any form.

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FACILITATION PAYMENTS

2.1 The Carlsberg Group prohibits the practice of facilitation payments.

DONATIONS

4.1 The Carlsberg Group shall not make political contributions or use donations to obtain improper business advantages.

CONFLICTS OF INTEREST

5.1 Employees in the Carlsberg Group shall not engage in activities that might create a conflict between personal interests and the Carlsberg Group’s business interests.

FRAUD

8.1 Employees in the Carlsberg Group shall not steal company assets or resources. Employees shall not use company assets or resources for anything other than Carlsberg business purposes. Employees shall observe the anti-fraud procedures described in the Carlsberg Group accounting policies.

CONFIDENTIAL INFORMATION

6.1 Employees in the Carlsberg Group shall not disclose or misuse confidential information obtained through business transactions or otherwise. Confidential relationships between the Carlsberg Group and its stakeholders shall be duly protected.

COMPETITION LAW

7.1 The Carlsberg Group and its employees shall ensure that Carlsberg’s business practices comply at all times with applicable competition rules and with the Carlsberg Competition Law Compliance Programme.

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3.1 Gifts, meals and entertain-ment offered or accepted by the Carlsberg Group and its employees must be appropri-ate. The Carlsberg Group and its employees shall not offer to or receive from public or private stakeholders, gifts, meals or entertainment that go beyond legitimate business purposes.

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SCOPE OF THE POLICYThe Carlsberg Group Business Ethics Policy applies to all employees in the Carlsberg Group, including subsidiaries and workers who are engaged infor-mally, on short-term contracts or on a part-time basis. Our joint ventures and business partners are strongly encour-aged to adopt and implement the Policy. All our suppliers and licensees (including agents and other third parties) have to comply with our Supplier and Licensee Code of Conduct, which sets out our social, environmental and ethical standards. Our subsidiaries are defined as companies in which Carlsberg A/S directly or indirectly owns or controls more than 50% of the voting rights or which it, in some other form, controls.

COMPLIANCE AND RESPONSIBILITY All subsidiaries within the Carlsberg Group shall comply with the provisions of the Policy as well as with national laws and regulations. It is the respon-sibility of the CEO of each subsidiary to ensure that the subsidiary in question complies with the Policy and with applicable law.

Should there be differences between the content of this Policy and national laws or other applicable standards, the more stringent requirements shall apply. Conflicts between the provi-sions of this Policy and national laws or other applicable standards shall be evaluated by Carlsberg Group Headquarters in cooperation with the Group companies.

APPLICATIONCarlsberg Group subsidiaries shall implement the Policy in their daily work. All Carlsberg Group subsidiaries shall take appropriate action to ensure that the provisions of this Policy are communicated to their employees in their own language. Compliance with the Policy and the Guidelines shall be regularly tracked and relevant correc-tive action plans identified and implemented.

WHISTLEBLOWING LINETo ensure the fullest commitment to this Policy, an incident reporting line has been established. This can be used by any employee who wishes to report knowledge or suspicion of behaviour that they believe contra-dicts this Policy or the Business Ethics Guidelines. This could be situations, events or actions involving individuals or groups that might:• have a negative impact (financial,

reputational or otherwise) for a Carlsberg company, its shareholders or the Carlsberg Group as a whole; or

• are detrimental to morale, produc-tivity or personal safety.

The system is carefully designed to maintain confidentiality and anonym-ity at every step. Step-by-step instruc-tions ensure that any reports made are submitted in a secure way.

Reporting is easy. Simply access www.whistleblower.carlsberggroup.com and complete a report (online or by phone). This report will be followed-up by Group Internal Audit 5-6 working days later.

For more information on the Carlsberg Group Whistleblower system, contact Group Internal Audit: whistleblower@carlsberg.com

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Valid for: Carlsberg Group and subsidiariesApproved by: Executive CommitteeDocument type: Policy – level 1Reference: Group CSR PoliciesVersion: 002Approval date: 01.01.2014

The Carlsberg Group shall periodically review the Business Ethics Policy and Guidelines in order to ensure their continued adequacy and relevance for our business. The most recent version of each will always apply.

Carlsberg Group100 Ny Carlsberg Vej

1799 Copenhagen VDenmark

Phone +45 3327 3300Fax +45 3327 4808

www.carlsberggroup.com