Supplier Code of Conduct

SUPPLIER CODE OF CONDUCT

Philip Morris USA • U.S. Smokeless Tobacco Company • John Middleton Ste. Michelle Wine Estates • Philip Morris Capital Corporation • Helix Innovations Our companies are committed to responsibly providing adult tobacco and wine consumers with superior branded products. It is important that our Suppliers understand that we are concerned not only with business results but with how those results are achieved.

We develop and maintain business relationships with Suppliers Respect for people is fundamental to the way we conduct who share our commitment to: business. Our expectations for our Suppliers are guided by the Universal Declaration of Human Rights and the International § Conduct business in a responsible manner in compliance with applicable laws Labour Organization (ILO) Declaration of Fundamental Principles and Rights at Work. § Respect the rights of workers Our Companies take a risk-based approach to monitoring and § Comply with applicable environmental laws and regulations assessing Supplier compliance with our contracts and this and aim to reduce the environmental impact of their Code. We believe Suppliers share this responsibility, should activities work cooperatively with us and endeavor to have systems § Implement management and monitoring practices to and personnel in place to monitor compliance and drive ensure compliance with contracts and applicable laws continuous improvement.

Altria’s Supplier Code of Conduct | 2 At the Altria family of companies, we believe in operating with integrity, trust, and respect. These values guide our behavior as we pursue our mission and our business strategies. Altria’s Supplier Code of Conduct builds upon this strong foundation.

requirements. The Supplier Code does not alter contractual Application terms or constitute express or implied contractual obligations The Supplier Code applies to all Suppliers that provide goods or contracts of employment. and services to the Altria family of companies. We expect our Suppliers to hold their supply chain, including subcontractors, to the same standards contained in this Supplier Code. Laws and Regulations Supplemental guidelines for select Suppliers, such as those Suppliers must comply with all applicable federal, state, covered by Altria’s Tobacco Good Agricultural Practices local, and foreign laws. Suppliers with operations outside the Program guidelines or the Responsible Business Alliance® United States must also comply with the applicable laws (RBA) Code of Conduct, may also apply. in the countries in which they operate. If the standards or The Supplier Code provides guidelines for business conduct requirements set forth in this code or in the contract are but does not replace the specific requirements in supplier greater than applicable law, then the Supplier shall follow the contracts. Suppliers must always comply with contractual higher standard.

Fair Employment and Workplace Conduct

HARASSMENT, ABUSE, AND DISCRIMINATION FORCED OR COMPULSORY LABOR Suppliers shall promote a work environment free from verbal, Suppliers must not use forced or compulsory labor or engage physical, or mental abuse, threats, violence, or any form of in the trafficking of persons. harassment during employment or recruitment. WAGES, BENEFITS, AND WORKING HOURS Employees shall not be subject to unlawful discrimination. Suppliers must comply with all applicable laws governing wage Employees shall not be subject to discrimination based on, and working hour requirements, including compensation, but not limited to, the following: race, color, age, gender, sexual benefits, and overtime. orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, HIRING AND TERMINATION union membership, covered veteran status, or marital status. Suppliers must comply with applicable laws governing eligibility for employment, recruitment, and termination. CHILD LABOR AND YOUNG WORKERS Suppliers must comply with the minimum age requirements FREEDOM OF ASSOCIATION as prescribed by applicable laws and regulations. Suppliers Suppliers are encouraged to respect legal rights of employees must adhere to our contracts or other applicable supplemental to join or not to join any lawful association without fear of guidelines which may provide standards at a higher level. reprisal or intimidation.

3 | Altria’s Supplier Code of Conduct We encourage Suppliers to take into account the environmental impact in business decision-making and consider opportunities for conservation of natural resources, recycling, reuse, source reduction, and pollution prevention and control.

Safety, Health, and Environmental

SAFETY AND HEALTH THE ENVIRONMENT Suppliers must comply with applicable safety and health laws Suppliers must comply with applicable environmental laws and regulations and regulations. Altria and its companies strive for a workplace culture in which Altria and its companies are also committed to complying each employee works toward the goal of an injury-free career. with applicable environmental regulations, reducing the Our companies are committed to the prevention of workplace environmental impact of its businesses, and promoting the injuries and illnesses, and to compliance with applicable laws sustainability or the natural resources on which we depend. We and company policies related to employee safety and health. encourage Suppliers to take into account the environmental Suppliers must comply with applicable safety and health laws impact in business decision-making and consider opportunities and regulations. Suppliers shall assure safe and healthy work for conservations of natural resources, recycling, reuse, source places to reduce the risk of accidents, injuries, and exposure. reduction, and pollution prevention and control. We encourage Suppliers to implement and have in place a performance monitoring program to account for aspects of their safety, health, and environmental programs.

Altria’s Supplier Code of Conduct | 4 Business Ethics and Compliance Honesty, integrity, and transparency in business operations competition. Suppliers must not offer our employees any provide the foundation for our business relationships. Suppliers confidential information about a competitor of an Altria shall commit to the highest standards of ethical conduct and company. business practices. RECORDS MANAGEMENT SECURITIES AND INSIDER TRADING LAWS Suppliers must maintain the confidentiality of trade secrets and Suppliers may learn of material nonpublic information during other proprietary information. Suppliers must also preserve the course of their work for us. They may not use or share that and/or dispose of Altria company records in compliance with information to trade or enable others to trade in the securities their contractual obligations. of Altria or any other company. DATA PRIVACY AND INFORMATION SECURITY ILLEGAL PAYMENTS, CORRUPTION, AND BRIBES Suppliers must comply with all applicable data privacy and Suppliers must not engage in illegal payments or corruption, information security laws and regulatory requirements including extortion, fraud, embezzlement, bribery, and regarding the collection, use, maintenance, transfer, sharing, kickbacks. Suppliers must comply with all applicable disclosure, and disposal of personal and/or confidential prohibitions and laws, including the Foreign Corrupt Practices information. Suppliers must also protect the personal and/ Act and any applicable equivalent non-U.S. law. or confidential information they maintain on behalf of an Altria company from unauthorized access, destruction, use, PROHIBITED PERSONS modification, and disclosure. In addition, Suppliers must comply Suppliers must ensure that neither they nor their officers nor with other contractual obligations related to data privacy and directors nor owners appear on any applicable sanctions information security. list. Some examples may include, but are not limited to, the following: Specially Designated Nationals (SDN) and Other PROTECTION OF IDENTITY AND NON-RETALIATION Blocked Persons list, the Sanctions Programs list, and the Suppliers shall ensure confidentiality, anonymity, and protection non-SDN Entities list, all maintained by the U.S. Department of from retaliation of any employee, who, in good faith, raises a Treasury, and the Denied Persons list maintained by the Bureau concern or reports suspected misconduct, unless prohibited of Industry and Security. by law.

GIFTS FISCAL INTEGRITY Our policies place significant restrictions on the types of Suppliers must maintain accurate books and records in gifts and entertainment that our employees are permitted compliance with all applicable laws, regulations, and to accept. Suppliers must not offer any gift or entertainment contractual obligations. to our employees that could be construed as an attempt to secure favorable treatment. Cash or cash equivalents (e.g., INTELLECTUAL PROPERTY gift certificates) as gifts to our employees are not allowed. Suppliers must respect and protect the intellectual property Suppliers must not provide any entertainment or gifts at all to rights of each of the Altria companies and other persons and/ any government official for or on behalf of an Altria company. or entities.

Similarly, Suppliers must not make any direct or indirect SOURCING OF RAW MATERIALS political contribution or expenditure for or on behalf of an Altria Suppliers shall exercise due diligence, as applicable, on the company. sourcing of conflict minerals (tantalum, tin, tungsten, and gold) and perform a reasonable country of origin inquiry ANTITRUST AND COMPETITION LAWS Suppliers must uphold applicable standards of fair business, with respect to such conflict minerals, including requiring its advertising, and competition. Suppliers must not enter into suppliers and sub-suppliers to engage in a similar agreements or actions that illegally restrain trade or restrict due diligence.

5 | Altria’s Supplier Code of Conduct Our Suppliers’ diversity contributes to our companies’ success. Our companies are committed to using a diverse base of Suppliers within our supply chain, including minority, women, LGBT, and veteran-owned businesses.

Supplier Diversity and Inclusion

Our Suppliers’ diversity contributes to our companies’ success. regional, and national organizations that work to increase Our companies are committed to using a diverse base of procurement and business opportunities for minority, women, suppliers within our supply chain, including minority, women, LGBT, and veteran-owned businesses. LGBT, and veteran-owned businesses. We also encourage Suppliers to set annual goals and develop Suppliers are encouraged to develop mutually beneficial and metrics to track spending with diverse Suppliers. successful relationships with diverse Suppliers by including them in the supplier selection process and to support local,

Altria’s Supplier Code of Conduct | 6 Monitoring and Assessments

Suppliers are encouraged to review compliance on a periodic When we learn of noncompliance issues, we communicate basis and designate personnel who shall be responsible for them to Suppliers. Suppliers shall take corrective actions to monitoring compliance with contractual obligations and this address non-compliance issues and keep us informed of their Supplier Code. remediation efforts. We reserve any and all contractual rights to Altria companies and appropriate functions may conduct halt business with Suppliers if remediation or abatement efforts periodic supplier performance reviews, assessments, and to achieve compliance are not effective or timely. We take a on-site visits. Falsification of records or misrepresentation of continuous improvement approach and work with Suppliers to conditions or practices in Supplier’s operations is unacceptable. improve their practices.

Raising Concerns and Reporting Potential Misconduct

To report concerns or a possible violation of the Supplier For suppliers in all other locations, download the list of toll-free Code, Suppliers are encouraged to work with their primary numbers from www.AltriaIntegrityWebLine.com or follow the Altria contact in resolving their concern. If that is not possible instructions to submit a report online. or appropriate or the Supplier wishes to raise an issue Altria will maintain confidentiality to the extent possible and anonymously, the Supplier should contact the Altria Integrity will not tolerate retaliation against any individual who makes a HelpLine / WebLine (available 24-hours-a-day, seven-days-a- report in good faith. week): For suppliers inside the United States or Canada, call 1-877-781-9324 or submit a report online at www.AltriaIntegrityWebLine.com.

7 | Altria’s Supplier Code of Conduct www.altria.com