Craft Brewers Alliance, Inc

CRAFT BREWERS ALLIANCE, INC.

CODE OF CONDUCT AND ETHICS For Employees, Officers and Members of the Board of Directors (Updated July 1, 2008)

Craft Brewers Alliance, Inc. (CBAI) believes that the long-term success of our Company, our employees and our shareholders is contingent upon employing only the highest of standards of conduct in all business dealings. These standards, which are articulated in this Code of Conduct and Ethics (the “Code”), are founded upon the following key principles:

 Complying with all applicable laws and regulations in all of the Company’s operations;  Exercising good judgment and conducting business with the highest standards of honesty, integrity and fairness; and  Paying regular attention to all legal and ethical boundaries.

While this Code cannot and is not intended to address every situation, it is intended to summarize the broad principles by which our employees, officers and directors should conduct themselves. The Code applies to Craft Brewers Alliance, Inc. (“We” “Us” “CBAI” or the “Company”) and to all our employees, officers and directors (“you” “your” or “Employees”). Compliance with this Code is required, and those who violate the standards in this Code will be subject to disciplinary action, up to and including termination of employment. This Code also applies to the Company agents and representatives, including consultants.

It is essential that you remain alert for possible breaches of this Code, whether they are a result of oversight or intention. The Company has established an Ethics Committee (the “Committee”) to address questions and concerns about this Code and its application in every day business dealings. If you have questions regarding this Code, or if you need to report possible violations of the Code, you should contact the Committee or any individual on the Committee. It is the policy of the Company not to tolerate retaliation for reports of misconduct made in good faith. You may report ethical violations in confidence and without fear of retaliation.

The Committee is comprised of a representative from the Human Resources Department, the Finance Department, the Operations Department, the Sales and Marketing Department, and the Board of Directors.

1. Compliance with Laws, Rules and Regulations. The Company is subject to federal, state and local laws in the cities and states where we operate. Violation of governing laws and regulations is unethical and subjects the Company to significant risks in the form of fines, penalties and damaged reputation. All Employees must respect and comply with applicable laws, regulations and corporate policies.

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Although you are not expected to know the details of all laws, rules and regulations in the cities and states where we operate, it is important to know enough to determine when to seek advice from supervisors, the Committee or other appropriate personnel.

2. Conflicts of Interest. Conflicts of interest can compromise an individual’s business ethics. A conflict of interest exists when a person’s private interests interferes, deviates or conflicts in any way with the Company’s interests, or gives the appearance of being a conflict. When you make decisions on behalf of the Company, the decisions must be in the best interests of the Company. You should take great care to insure that personal relationships or benefits do not influence your decision-making process.

You should avoid any relationship that would cause a conflict of interest with your duties and responsibilities at CBAI. You are expected to disclose to the Committee any situations that may involve inappropriate or improper relationships affecting you personally, affecting any member of your immediate family or household, or affecting others or those with whom the Company does business. Waivers of conflicts of interest involving executive officers require the approval of the Board of Directors.

It is not possible to list all conflicts of interest, but listed below are some areas where conflicts are possible. In the end, it is your responsibility to avoid any situation that could appear to be a conflict of interest. Any Employee that becomes aware of a conflict or a potential conflict of interest should bring it to the attention of a supervisor or the Committee.

Interest in Businesses Outside of CBAI: Employees must avoid any direct or indirect relationship with organizations that could cause divided allegiance. While this Code doesn't mean that family members are prohibited from being employed by one of the Company's customers, competitors, or suppliers, it does mean that the relationship must be disclosed to the Committee, and that the individual must avoid conducting Company business with the organization with which the conflict exists, unless he or she has prior written permission from the Committee.

Outside Directorships: Employees who serve on outside boards, whether the organization is for-profit or not-for-profit, are required to notify the Committee prior to committing to serve. Employees may not accept a position as an outside director of any current or likely competitor of the Company.

Employees may not receive any form of compensation (including stock options, stock or cash) for service on a board of directors of a company if the service is at the request of the Company. When membership on a Board of Directors is other than at the Company's request, even if no compensation is received, the CBAI Employee is expected to disqualify him- or herself from any involvement in the Company's relationship with that company in order to avoid even the appearance of a conflict of interest. While membership on a board of directors can be an opportunity to provide - 2 - CRAFT BREWERS ALLIANCE, INC.

CODE OF CONDUCT AND ETHICS For Employees, Officers and Members of the Board of Directors (Updated July 1, 2008) knowledge and to broaden the Employees’ experience, an Employee should avoid situations where the other company expects to use the person's board membership as a way to gain access or to influence the Company’s decisions.

At any time, CBAI may withdraw an approval of an outside directorship.

Investments in Public Companies: Employees may have passive investments in public companies as long as: (1) the investment is not so large (either in actual dollars or relative to the Employee’s total investment portfolio) that it gives the appearance of a conflict of interest; or (2) the investment in any single company is not more than one percent of total outstanding shares of the company. Any such investment must not involve the use of confidential "inside" or proprietary information, such as confidential information about the other company that might have been acquired in conjunction with the Company's relationship with the other company. Investments in diversified publicly traded mutual funds are not deemed subject to these conflict of interest guidelines, provided confidentiality requirements are observed.

Investments in Private Companies: CBAI Employees will occasionally find themselves in a position to invest in CBAI partners or customers. It is critical that Employees offered such opportunities recognize the potential conflict of interest that may result in these situations. Accountability to Company shareholders is first. Investing in companies that CBAI has an actual or potential business relationship with may not be in the best interests of CBAI shareholders. The following guidelines are intended to cover such circumstances:

CBAI Employees may not invest in privately held companies that are the Company’s customers, partners or suppliers without prior disclosure to the Committee and the written consent of the Committee. In such cases, approval is likely to be denied.

If an investment is made and/or approval is granted, and the employee at some time later finds him- or herself in a potentially conflicted position due to his or her job responsibilities or those of others under his/her supervision, the CBAI employee is expected to withdraw him- or herself from any involvement in the Company's relationship with that company. If the conflict involves a primary job responsibility, it may be necessary for the Employee to withdraw his investment.

If a conflict of interest arises as a result of a change in job responsibilities, the Employee should disclose the situation in writing to the Committee. The Committee will make an effort to resolve the situation as fairly as possible.

Where the Company has made an investment in a company, permission must be obtained before an Employee invests in that company. When a CBAI Employee is placed on a board of directors or advisory board to represent the Company, such

Employee cannot make an investment in that company without the Committee’s approval; and he or she may not receive compensation for such participation.

Honoraria: A normal part of certain Employees’ job responsibilities includes speaking at events. Because Employees will be compensated by the Company for most or all of the time required to prepare, attend, and deliver presentations, Employees should not request a fee or receive any form of compensation from the organization that requested the speech, unless the Employee first receives express authorization from the Committee.

Inventions, Books, and Publications: Prior to developing for personal gain any product, software, or intellectual property that may be related to the Company's current or potential business, Employees must receive written approval from the Committee.

Proper Payments: All CBAI Employees should pay for and receive only that which is proper. CBAI Employees should not make payments or promises to influence another's acts or decisions, and CBAI Employees must not give gifts beyond those extended in normal business. CBAI Employees must observe all government restrictions on gifts and entertainment. Employees should not receive payments of any kind from CBAI customers.

Favors, Gifts, and Entertainment: CBAI Employees and members of their families must not give or receive valuable gifts to or from any person associated with the Company’s vendors or customers or potential vendors or customers.

This is not intended to preclude the Company from receiving or evaluating appropriate complimentary products or services. Nor is it intended to preclude the Company from making a gift to a company or organization, provided that the gift is openly given, with full knowledge by the company or organization, and is consistent with applicable law. Any gifts received should be turned over to the Employee’s supervisor or Human Resources for appropriate disposition. In all cases, the exchange of gifts must be conducted so there is no appearance of impropriety. Gifts may only be given in accordance with applicable laws. Marketing novelties, favors and entertainment are allowed when the following conditions are met:  They are consistent with the Company's business practices;  They do not violate any applicable law, such as state and federal procurement laws and regulations;  They are of limited value ($100 U.S. or less); and  Public disclosure would not embarrass CBAI.

Industry Associations: Membership on boards of industry associations generally do not present financial conflicts of interest. However, Employees should be sensitive to possible conflicts with the Company's business interests, if, for instance, the

CODE OF CONDUCT AND ETHICS For Employees, Officers and Members of the Board of Directors (Updated July 1, 2008) association takes a position adverse to the Company's interests or those of key customers.

Supervisory Relationships with Family Members: Supervisory relationships with family members present special workplace problems, including a conflict of interest, or at least the appearance of conflict, in various personnel decisions that the supervisor makes. Accordingly, CBAI Employees must avoid a direct reporting relationship with any member of their family or others with whom they have a significant relationship. If such a relationship exists or occurs, the employee must report it in writing to the Committee.

3. Insider Trading. Employees who have access to material, non-public information relating to CBAI are not permitted to use or share that information for stock trading purposes or for any other person except the conduct of the Company’s business. All non-public information about the Company should be considered confidential information. To use non-public confidential information about CBAI for your financial personal benefit is both unethical and illegal. This policy also applies to trading in the securities of any other company, including our customers or suppliers, if you have material, non-public information about that company which you obtained in the course of your employment with the Company. Even the appearance of an improper transaction must be avoided. Violations of insider trading laws may be punishable by fines and/or imprisonment.

Besides the obligation to refrain from trading in CBAI securities while in possession of material, non-public information, you are also prohibited from “tipping” others who might make an investment decision based on the non-public information that you hold. Tipping is a form of insider trading and is both unethical and illegal. You should be careful to avoid discussing sensitive information in any place (for instance, at lunch or in elevators) where others may hear such information.

All Employees should consult the Company's Stock Trading Policy before trading in CBAI securities.

4. Government Business. Employees should understand that special requirements might apply when contracting with any government body (including national, state, municipal, or other similar government divisions in local jurisdictions). Because government officials are obligated to follow specific codes of conduct and laws, special care must be taken in government procurement. Some key requirements for doing business with a government are:

Not offering or accepting kickbacks, bribes, gifts, gratuities or anything else of value with the intent of obtaining favorable treatment from the recipient (a gift that is customary in the business sector may be perceived as a bribe by a government official); - 5 - CRAFT BREWERS ALLIANCE, INC.

Hiring present and former government personnel may only occur in compliance with applicable laws and regulations (as well as consulting Human Resources).

5. Competition and Fair Dealing. CBAI strives to outperform our competition fairly and honestly. Stealing proprietary information, possessing trade secret information or inducing such disclosures by current or past employees of our customers, competitors, vendors, and others with whom we do business is prohibited. Each Employee has the duty to respect and protect the rights of our customers, vendors, competitors and employees. No Employee should take advantage of anyone through manipulation, concealment, abuse of privileged information or otherwise.

6. Confidentiality. Employees must maintain the confidentiality of all confidential information entrusted to them by the Company or by our customers, except when disclosure is authorized by the Committee or required by applicable laws or regulations. The use of confidential and proprietary information, whether the Company's or a third party’s, and whether or not covered by a confidentiality agreement, should be disclosed only to those Employees who need access to the information to perform their jobs and should not be used or copied by any Employee except as permitted by CBAI or the third-party owner. The obligation to preserve confidential information continues even after your employment with CBAI ends.

7. Proprietary Information. Proprietary information is defined as information that was developed, created, or discovered by the Company, or that became known by or was conveyed to the Company, that has commercial value in the Company’s business. The Company's business and business relationships center on the confidential and proprietary information of CBAI and of those with whom we do business. All Employees should seek to protect our proprietary information and the proprietary information of our customers and vendors. Any unauthorized use or distribution of this information violates Company policy, and could also be illegal or result in civil or criminal penalties. 8. Discrimination and Harassment. CBAI believes that diversity within our Company is an important asset. We are firmly committed to providing equal opportunity in all areas of employment and will not tolerate any unlawful discrimination or harassment of any kind. A broader discussion is on pages 5-6 of this Handbook.

9. Political Contributions. No Company assets--including Employees’ work time, use of CBAI premises, use of Company equipment, or direct monetary payments--may be contributed to any political candidate, political action committees (aka “PACs”), political party, or ballot measure without the permission of the Committee. Of course, Employees may participate in any political activities of their choice on an individual basis, with their own money and on their own time.

10.Record Keeping. CBAI requires honest and accurate recording and reporting of all business information. All of the Company’s books, records, accounts and financial statements must be maintained in reasonable detail, and must appropriately reflect the Company’s transactions and must conform to both applicable legal requirements and the Company’s system of internal controls. All Company business records and communications, including emails, internal memos and formal reports, should avoid exaggeration, derogatory remarks, guesswork or inappropriate characterizations of people and companies that might be misunderstood.

11.Special Ethics Obligations for Employees with Financial Reporting Responsibilities. As a public company, it is critical that the Company’s filings with the Securities and Exchange Commission are accurate and timely. You may be called upon to provide information to assure that the Company’s public reports are complete, fair and understandable. CBAI expects all Employees to take this responsibility very seriously and to provide prompt and accurate answers to inquiries related to the Company’s public disclosure requirements.

The Finance Department bears a special responsibility for promoting integrity throughout the organization, with responsibilities to parties both inside and outside of CBAI. The Chief Executive Officers and Finance Department staff have a special role - 7 - CRAFT BREWERS ALLIANCE, INC.

– both to adhere to these principles themselves and also to ensure that a culture exists throughout the Company as a whole that ensures the fair and timely reporting of the Company's financial results and condition. Because of this special role, the Chief Executive Officers and all members of the Company's Finance Department are bound by the following Financial Code of Ethics, and by accepting this Code, each agrees that he or she will:

 Promptly report to the Committee and/or the Chairman of the Audit Committee any conduct that the individual believes to be a material violation of the securities or other laws, rules or regulations, a violation of law or business ethics or of any provision of this Code and these additional requirements, including any transaction or relationship that reasonably could be expected to give rise to such a violation;  Promptly report to the Committee and/or the Chairman of the Audit Committee any material information which he or she may become aware that affects the disclosures made by the Company in its public filings;  Promptly report to the Committee and/or the Chairman of the Audit Committee any information he or she may have regarding (a) significant deficiencies in the design or operation of internal controls which could adversely affect the Company’s ability to record, process, summarize and report financial data or (b) any fraud, whether or not material, that involves management or any Employee that has a significant role in the Company’s financial reporting, disclosures or internal controls;  Act with honesty and integrity, avoiding actual or apparent conflicts of interest in personal and professional relationships;  Provide information that is accurate, complete, objective, relevant, timely and understandable to insure full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files with, or submits to, government agencies and in other public communications;  Comply with rules and regulations of federal, state and local governments, and other appropriate private and public regulatory agencies;  Act in good faith, responsibly, with due care, competence and diligence, without misrepresenting material facts or allowing one’s independent judgment to be subordinated;  Respect the confidentiality of information acquired in the course of one’s work except when authorized or otherwise legally obligated to disclose such information. Confidential information acquired in the course of one’s work will not be used for personal advantage;  Share knowledge and maintain skills important and relevant to shareholder’s needs;  Proactively promote and be an example of ethical behavior as a responsible Employee among peers, in the work environment and the community;  Achieve responsible use of and control over all assets and resources of the Company that are employed or entrusted.

Violations of this Financial Code of Ethics, including failures to report potential violations by others, will be viewed as a severe disciplinary matter that may result in personnel action, up to and including termination of employment. If you believe that a violation of the Financial Code of Ethics has occurred, please contact any member of the Committee. You may also contact the Audit Committee of the Board of Directors at:

 Audit Committee of the Board of Directors Attention: Chairman Craft Brewers Alliance, Inc. 929 North Russell Street Portland, OR 97227 425.483.3232, ext. 1127 [email protected]

 If you are concerned about maintaining anonymity, you may send correspondence by any of the following means: o Delivered confidentially, in person, by internal mail, by regular mail; o Electronic mail; o Anonymously by mail; o Anonymously through the Craft Brewers Alliance, Inc. Confidential Ethics Web Form (http://corpgov.aptela.com/7319265/); or o Anonymously through the Craft Brewers Alliance, Inc. Corporate Governance Hotline at 1.888.449.9595.

12.Waivers of the Code. Any waiver of this Code for executive officers or directors may be made only by the Board of Directors and will be promptly disclosed as required by law or NASD regulation.

13.Reporting Requirements. It is the responsibility of every director, officer, and Employee of CBAI to immediately report to the Committee illegal, unethical or other improper conduct of which he or she has knowledge, including any violation of this Code or the Financial Code of Ethics, whether the improper conduct was committed by a CBAI Employee, an employee or official of any level of government, or any other individual or business entity.

To facilitate and encourage the reporting of illegal, unethical or other improper conduct, CBAI has established a dedicated toll-free number (1.888.449.9595) that is accessible at all times providing a confidential way for employees to report problems to the Audit Committee. It is completely secure, encrypted infrastructure. Submissions are digitally recorded and sent by e-mail as either a distorted audio file or text transcript of the call to maintain anonymity. All complaints will go directly to the

CODE OF CONDUCT AND ETHICS For Employees, Officers and Members of the Board of Directors (Updated July 1, 2008) members of the Audit Committee, Human Resources, the Controller and the Chief Financial Officer.

It is against Company policy to retaliate against any Employee for good faith reporting of violations of the Code or other illegal, unethical or improper conduct. You should also be assured that CBAI will maintain all reports of improper conduct in the strictest confidence to the extent permitted by law.

Members of the Ethics Committee Stacia Bird, Human Resources 503.802.1293 [email protected]

Jared Jones, Director of Internal Audit 425.483.3232 ext 1133 [email protected]

Kevin Kelly, Member of Board of Directors 425.483.3232 ext 1127 [email protected]

Doug MacNair, Plant Manager – New Hampshire Brewery; Redhook Brewmaster 603.430.8600 ext 2328 [email protected]

Mark Meline, Retail Marketing Manager 425.483.3232 ext 1222 [email protected]

Mark Moreland, Chief Financial Officer (effective August 16, 2008) 503.331.7258 [email protected]

Amanda Telford, General Manager – New Hampshire 603.430.8600 ext 2320 [email protected]

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