Mitchells & Butlers plc 27 Fleet Street and Social Birmingham B3 1JP Tel: +44 (0) 870 609 3000 Fax: +44 (0) 121 233 2246 www.mbplc.com/socialresponsibility Responsibility Policy Mitchells & Butlers - Alcohol and Social Responsibility Policy 2007 Introduction

As the leading operator of around 2,000 In recognition of the implementation of managed pubs and pub restaurants in the UK, this policy, Mitchells & Butlers is pleased Policy Highlights Mitchells & Butlers is committed to leading to have been awarded the title of Britain's ! ! best practice in the responsible retailing of Most Responsible On-Trade Drinks Retailer The Company is committed to the We do not offer any incentives alcohol. at the inaugural Responsible Drinks responsible retailing of alcohol and to our customers to drink irresponsibly Retailing Awards. recognises that it is a fundamental part ! Our staff can easily access information We operate in a highly regulated industry and of what we do, every day recognise that attached to the grant of our Across the country, individual pubs have about units of alcohol and alcohol by ! licences is the primary obligation to ensure gained recognition from city councils and We do not serve alcohol to anyone whom volume in order to provide that the responsible operation of our premises at the police for running a safe and we believe to be intoxicated information to guests all times for guests, staff and the wider responsible business via the 'Best Bar ! ! community. None' award scheme. We do not serve customers whom we We value and respect the partnerships believe to be under 18 - nor to anyone our managers have with local Mitchells & Butlers has had a comprehensive We are always mindful of our duty of care whom we suspect of passing alcohol to authorities policy for the responsible sale of alcohol since as a retailer of alcohol and, through under 18s ! Our senior managers are actively 2000. This policy aims to ensure that all of our training and the use of our own and trade ! licensed premises are operated responsibly, association-produced materials, we are If a customer looks under 21 we will ask involved in setting industry standards safely and within the parameters of the law, able to implement initiatives aimed at for a recognised form of ID and lead by example and provide an inclusive environment for the combating under age and irresponsible ! sensible, controlled consumption of alcohol. drinking. We do not permit promotions limited to very short periods of time such as happy hours

Alcohol and Social Responsibility Policy

1. Mitchells & Butlers is committed to operating 2. Mitchells & Butlers will at all times observe the all of its licensed premises responsibly, safely law with regard to the sale of alcohol and all and within the law. We support the four prime other products by: objectives of the Licensing Act 2003: ! Not serving guests who are intoxicated ! The prevention of crime and disorder ! Not serving alcohol to people who are under ! Public safety 18 years old and, where there is any doubt, ! The prevention of public nuisance following our Operational Guidelines for under 18s (attached) ! The protection of children from harm ! Not serving alcohol to customers who are over and we seek always to work closely and 18 but whom we believe may be passing their constructively with the key authorities, purchase on to under 18s. We welcome all including Police, Fire, Environmental Health moves towards the introduction of a nationally and Local Authorities, in pursuit of these recognised, mandatory proof of age card. A objectives. statement of the Company's responsibility The Company does not operate any 24 hours towards under 18s is available on our website licences. www.mbplc.com ! We support regional crime and disorder Supporting 'test purchasing' conducted by partnerships and aim to participate fully in the police and licensing authorities as a way of drive against '' and its related helping to enforce the law effects, as outlined in the Alcohol Harm ! Observing all other conditions of licensing law Reduction Strategy for England. It is Company policy for all managers to join and support a local 'Pubwatch' scheme if one exists. Mitchells & Butlers - Alcohol and Social Responsibility Policy 2007 Introduction

As the leading operator of around 2,000 In recognition of the implementation of managed pubs and pub restaurants in the UK, this policy, Mitchells & Butlers is pleased Policy Highlights Mitchells & Butlers is committed to leading to have been awarded the title of Britain's ! ! best practice in the responsible retailing of Most Responsible On-Trade Drinks Retailer The Company is committed to the We do not offer any incentives alcohol. at the inaugural Responsible Drinks responsible retailing of alcohol and to our customers to drink irresponsibly Retailing Awards. recognises that it is a fundamental part ! Our staff can easily access information We operate in a highly regulated industry and of what we do, every day recognise that attached to the grant of our Across the country, individual pubs have about units of alcohol and alcohol by ! licences is the primary obligation to ensure gained recognition from city councils and We do not serve alcohol to anyone whom volume in order to provide that the responsible operation of our premises at the police for running a safe and we believe to be intoxicated information to guests all times for guests, staff and the wider responsible business via the 'Best Bar ! ! community. None' award scheme. We do not serve customers whom we We value and respect the partnerships believe to be under 18 - nor to anyone our managers have with local Mitchells & Butlers has had a comprehensive We are always mindful of our duty of care whom we suspect of passing alcohol to authorities policy for the responsible sale of alcohol since as a retailer of alcohol and, through under 18s ! Our senior managers are actively 2000. This policy aims to ensure that all of our training and the use of our own and trade ! licensed premises are operated responsibly, association-produced materials, we are If a customer looks under 21 we will ask involved in setting industry standards safely and within the parameters of the law, able to implement initiatives aimed at for a recognised form of ID and lead by example and provide an inclusive environment for the combating under age and irresponsible ! sensible, controlled consumption of alcohol. drinking. We do not permit promotions limited to very short periods of time such as happy hours

Alcohol and Social Responsibility Policy

1. Mitchells & Butlers is committed to operating 2. Mitchells & Butlers will at all times observe the all of its licensed premises responsibly, safely law with regard to the sale of alcohol and all and within the law. We support the four prime other products by: objectives of the Licensing Act 2003: ! Not serving guests who are intoxicated ! The prevention of crime and disorder ! Not serving alcohol to people who are under ! Public safety 18 years old and, where there is any doubt, ! The prevention of public nuisance following our Operational Guidelines for under 18s (attached) ! The protection of children from harm ! Not serving alcohol to customers who are over and we seek always to work closely and 18 but whom we believe may be passing their constructively with the key authorities, purchase on to under 18s. We welcome all including Police, Fire, Environmental Health moves towards the introduction of a nationally and Local Authorities, in pursuit of these recognised, mandatory proof of age card. A objectives. statement of the Company's responsibility The Company does not operate any 24 hours towards under 18s is available on our website licences. www.mbplc.com ! We support regional crime and disorder Supporting 'test purchasing' conducted by partnerships and aim to participate fully in the police and licensing authorities as a way of drive against 'binge drinking' and its related helping to enforce the law effects, as outlined in the Alcohol Harm ! Observing all other conditions of licensing law Reduction Strategy for England. It is Company policy for all managers to join and support a local 'Pubwatch' scheme if one exists. 3.Mitchells & Butlers operates a Responsible 4. In relation to the drinks we serve: I. Mitchells & Butlers' Responsible Pricing Pricing and Promotions Policy for all alcoholic ! Anti-drink/drive activities are encouraged and Promotions Policy drinks, the guiding principles of which are: and supported and a range of soft drinks All promotional activity will comply with the # Free drink vouchers are acceptable only ! To offer guests real service and real value is available Portman Group's Code of Practice and will if redemption is limited to one per person, at fair, competitive prices ! Tap water is offered free of charge therefore avoid: to be detailed in print on the terms and ! conditions of the voucher, and team To seek to encourage increasing numbers ! ! Association with anti-social behaviour or There will always be a choice of soft drink members are briefed in advance to be of guests to visit and return to Mitchells at less than the price of a pint of beer, even violence & Butlers pubs, rather than to seek to vigilant for any perceived abuse of the during promotions or where discounts are ! Appealing particularly to under 18s rather encourage increased consumption by offer's terms and conditions offered than to adults individual guests during any one visit ! ! ! ! Mitchells & Butlers uses toughened glass Purchase by or sale to under 18s No unreasonable price based volume To ensure guests are offered choice and widely and reviews usage on a regular basis value without inducements to drink to excess ! Association with illicit drugs inducements. For example: ! All of our pubs and pub restaurants serve ! ! Suggestion that alcohol can enhance mental # Shared drink serves such as cocktail Mitchells & Butlers is an active member of 175ml measures of wine as a standard size. or physical capabilities pitchers or pitchers of beer, which are for the British Beer & Pub Association (BBPA) 250ml measures may also be served consumption by groups of guests, will be at and has senior managers representing the ! Encouragement of illegal, irresponsible or ! Our standard spirit measure is a single 25ml prices which reflect reasonable discounts Company at policy-making level immoderate consumption from the price, were the component drinks ! We have played a central role in the formation to have been bought individually. For of the BBPA's code on responsible drinks In addition, we will not undertake: 5. Mitchells & Butlers is committed to educating, example, a four pint pitcher will be priced promotions, which is referred to as good ! training and supporting its managers and staff Promotions which involve driving in any so that the fourth pint is not 'free' – it will practice in the Government Guidance to so that they are able to carry out their duties way e.g. including cars as prizes be the sum of three pints at full price plus Local Authorities on the Licensing Act 2003 under this policy and the law. We are a ! Promotions which involve drinking games a positive contribution, usually at least ! registered training centre with the BII. Summary Furthermore, the BBPA, in conjunction such as a 'yard of ale' £0.50, from the fourth pint with other trade associations, has published details of the company's training programmes # A double measure of spirits that is at least a code called the 'Standards for the in this regard are attached. Any promotional activity must be approved £0.60 more than a single measure is Management of Responsible Drinks by the marketing director and observe the acceptable. A double represents around Promotions' which has been adopted by following additional Company guidelines: two units of alcohol, about the same as a a number of companies 6. We recognise that good management has a direct bearing on the security of our pubs and ! standard pint of lager ! The maximum serve of spirits in one glass All of Mitchells & Butlers' promotions pub restaurants. We only contract to use is a double measure comply with the BBPA code as a minimum security staff who have gained SIA accreditation. ! ! No time limited promotion, e.g. 'happy hours', ! No initial payment to obtain reduced price Mitchells & Butlers' detailed Responsible alcohol e.g. 'pay £10 and drink all you can’ will last for less than three hours Pricing and Promotions policy is attached ! ! Any single full serve size ! No 'free' alcohol inducements. No guest Mitchells & Butlers is a major funder of the should receive additional drink without priced below £1.25 will require the approval Drinkaware Trust, an independent, UK wide, asking for it and paying for it. For example: of the managing director public facing body with the objective of # ! All pub/bar specific promotional activity is positively changing public behaviour and No '2 for 1's', '3 for 2's', or 'buy 2 glasses, required to be agreed by the relevant retail the national to help reduce get the rest of the bottle free’ operations director alcohol misuse and minimise alcohol-related # Promotions involving a bottle of wine will harm. Our chief executive is an appointed be at a fixed price point and will not ! All promotions will take full account of both member of the Board of the Drinkaware Trust involve 'free' additional volume the substance and the spirit of this policy 3.Mitchells & Butlers operates a Responsible 4. In relation to the drinks we serve: I. Mitchells & Butlers' Responsible Pricing Pricing and Promotions Policy for all alcoholic ! Anti-drink/drive activities are encouraged and Promotions Policy drinks, the guiding principles of which are: and supported and a range of soft drinks All promotional activity will comply with the # Free drink vouchers are acceptable only ! To offer guests real service and real value is available Portman Group's Code of Practice and will if redemption is limited to one per person, at fair, competitive prices ! Tap water is offered free of charge therefore avoid: to be detailed in print on the terms and ! conditions of the voucher, and team To seek to encourage increasing numbers ! ! Association with anti-social behaviour or There will always be a choice of soft drink members are briefed in advance to be of guests to visit and return to Mitchells at less than the price of a pint of beer, even violence & Butlers pubs, rather than to seek to vigilant for any perceived abuse of the during promotions or where discounts are ! Appealing particularly to under 18s rather encourage increased consumption by offer's terms and conditions offered than to adults individual guests during any one visit ! ! ! ! Mitchells & Butlers uses toughened glass Purchase by or sale to under 18s No unreasonable price based volume To ensure guests are offered choice and widely and reviews usage on a regular basis value without inducements to drink to excess ! Association with illicit drugs inducements. For example: ! All of our pubs and pub restaurants serve ! ! Suggestion that alcohol can enhance mental # Shared drink serves such as cocktail Mitchells & Butlers is an active member of 175ml measures of wine as a standard size. or physical capabilities pitchers or pitchers of beer, which are for the British Beer & Pub Association (BBPA) 250ml measures may also be served consumption by groups of guests, will be at and has senior managers representing the ! Encouragement of illegal, irresponsible or ! Our standard spirit measure is a single 25ml prices which reflect reasonable discounts Company at policy-making level immoderate consumption from the price, were the component drinks ! We have played a central role in the formation to have been bought individually. For of the BBPA's code on responsible drinks In addition, we will not undertake: 5. Mitchells & Butlers is committed to educating, example, a four pint pitcher will be priced promotions, which is referred to as good ! training and supporting its managers and staff Promotions which involve driving in any so that the fourth pint is not 'free' – it will practice in the Government Guidance to so that they are able to carry out their duties way e.g. including cars as prizes be the sum of three pints at full price plus Local Authorities on the Licensing Act 2003 under this policy and the law. We are a ! Promotions which involve drinking games a positive contribution, usually at least ! registered training centre with the BII. Summary Furthermore, the BBPA, in conjunction such as a 'yard of ale' £0.50, from the fourth pint with other trade associations, has published details of the company's training programmes # A double measure of spirits that is at least a code called the 'Standards for the in this regard are attached. Any promotional activity must be approved £0.60 more than a single measure is Management of Responsible Drinks by the marketing director and observe the acceptable. A double represents around Promotions' which has been adopted by following additional Company guidelines: two units of alcohol, about the same as a a number of companies 6. We recognise that good management has a direct bearing on the security of our pubs and ! standard pint of lager ! The maximum serve of spirits in one glass All of Mitchells & Butlers' promotions pub restaurants. We only contract to use is a double measure comply with the BBPA code as a minimum security staff who have gained SIA accreditation. ! ! No time limited promotion, e.g. 'happy hours', ! No initial payment to obtain reduced price Mitchells & Butlers' detailed Responsible alcohol e.g. 'pay £10 and drink all you can’ will last for less than three hours Pricing and Promotions policy is attached ! ! Any single full serve size alcoholic drink ! No 'free' alcohol inducements. No guest Mitchells & Butlers is a major funder of the should receive additional drink without priced below £1.25 will require the approval Drinkaware Trust, an independent, UK wide, asking for it and paying for it. For example: of the managing director public facing body with the objective of # ! All pub/bar specific promotional activity is positively changing public behaviour and No '2 for 1's', '3 for 2's', or 'buy 2 glasses, required to be agreed by the relevant retail the national drinking culture to help reduce get the rest of the bottle free’ operations director alcohol misuse and minimise alcohol-related # Promotions involving a bottle of wine will harm. Our chief executive is an appointed be at a fixed price point and will not ! All promotions will take full account of both member of the Board of the Drinkaware Trust involve 'free' additional volume the substance and the spirit of this policy II. Operational Policy for under 18s Each member of retail staff receives a Appendix 1 Draught Beer & Cider comprehensive programme of training through Mitchells & Butlers will at all times observe the UNITS OF ALCOHOL PER DRINK Brand ABV% Units/ Units/ 'Stepping Stones'. This includes education as law and do everything we can to ensure that pint half pint to the legal requirements of their role, including alcohol is not served to people who are under their responsibilities not to serve under 18s and Carlsberg 3.80% 2.2 1.1 18 years old. those who are intoxicated. Carling 4.10% 2.3 1.2 If a guest appears to be under 21 then we As a matter of course, all staff, including door Becks Vier 4.00% 2.3 1.1 require proof that he/she is over 18. In these staff, are to be made aware of Mitchells & Amstel 4.10% 2.3 1.2 circumstances staff are required to: Butlers' legal and social obligations and of the Fosters 4.00% 2.3 1.1 ! Explain that it is against the law to sell alcohol need for proof of age. All new staff are to be Stella 5.10% 2.9 1.4 to under 18s trained and must sign the Server of Alcohol Premium Lager 5.00% 2.8 1.4 ! training form to confirm their training, before Ask for identification. Only three types are Tetley Smoothflow 3.60% 2.0 1.0 they are allowed to serve alcohol. acceptable: Worthington Creamflow 3.60% 2.0 1.0 # Proof of age card with 'PASS' accredited Regular updates are to be given at team John Smiths Extra Smooth 3.80% 2.2 1.1 hologram meetings on any articles on under age drinking Guinness 4.10% 2.3 1.2 which the Company may communicate in its # Strongbow 4.50% 2.6 1.3 International passport in-house newsletter, security and licensing # UK photograph driving licence newsletter or brand newsletters, or through communication from line management. Wine ! If a guest does not have identification, suggest they return with some and they will Last year, more than 3,000 members of our ABV% Units/ Units/ Units/ be served when they do retail staff completed the British Institute of 175ml 250ml 75cl Innkeeping's (BII) 'National Certificate for ! Be polite and tactful, but firm, when asking 9.00% 1.6 2.3 6.8 Personal Licence Holders', which is the for identification. Do not antagonise the 9.50% 1.7 2.4 7.1 recognised national qualification in the licensed situation if a guest becomes aggressive 10.00% 1.8 2.5 7.5 trade. and/or refuses to leave. Inform a member of 10.50% 1.8 2.6 7.9 management Mitchells & Butlers is recognised by the BII as 11.00% 1.9 2.8 8.3 a leading provider of training and is licensed ! It is best practice for staff to record instances 11.50% 2.0 2.9 8.6 accordingly to deliver the training in-house. where service has been refused for whatever 12.00% 2.1 3.0 9.0 reason Our retail staff can easily access information 12.50% 2.2 3.1 9.4 about units of alcohol and alcohol by volume 13.00% 2.3 3.3 9.8 for popular drinks brands in order to provide 13.50% 2.4 3.4 10.1 that information to guests. 14.00% 2.5 3.5 10.5 Individuals have a degree of personal 14.50% 2.5 3.6 10.9 III.Alcohol & Social responsibility – Staff Training responsibility for the amount of alcohol they With over 44,000 retail staff nationally, Mitchells consume. Our employees cannot offer advice to & Butlers is committed to comprehensive customers, for example, about the Government's Spirits training and development programmes. Sensible Drinking Message. Brand ABV% Single Double (25ml) (50ml) Baileys 17.00% 0.4 0.9 Malibu 21.00% 0.5 1.1 Pimms 25.00% 0.6 1.3 Southern Comfort 35.00% 0.9 1.8 Smirnoff Red 37.50% 0.9 1.9 Smirnoff Black 40.00% 1.0 2.0 Bacardi 37.50% 0.9 1.9 Gordons 37.50% 0.9 1.9 Others 40.00% 1.0 2.0

A “unit” is equivalent to 10ml of pure alcohol To calculate units: %ABV x Vol. in ml / 10 II. Operational Policy for under 18s Each member of retail staff receives a Appendix 1 Draught Beer & Cider comprehensive programme of training through Mitchells & Butlers will at all times observe the UNITS OF ALCOHOL PER DRINK Brand ABV% Units/ Units/ 'Stepping Stones'. This includes education as law and do everything we can to ensure that pint half pint to the legal requirements of their role, including alcohol is not served to people who are under their responsibilities not to serve under 18s and Carlsberg 3.80% 2.2 1.1 18 years old. those who are intoxicated. Carling 4.10% 2.3 1.2 If a guest appears to be under 21 then we As a matter of course, all staff, including door Becks Vier 4.00% 2.3 1.1 require proof that he/she is over 18. In these staff, are to be made aware of Mitchells & Amstel 4.10% 2.3 1.2 circumstances staff are required to: Butlers' legal and social obligations and of the Fosters 4.00% 2.3 1.1 ! Explain that it is against the law to sell alcohol need for proof of age. All new staff are to be Stella 5.10% 2.9 1.4 to under 18s trained and must sign the Server of Alcohol Premium Lager 5.00% 2.8 1.4 ! training form to confirm their training, before Ask for identification. Only three types are Tetley Smoothflow 3.60% 2.0 1.0 they are allowed to serve alcohol. acceptable: Worthington Creamflow 3.60% 2.0 1.0 # Proof of age card with 'PASS' accredited Regular updates are to be given at team John Smiths Extra Smooth 3.80% 2.2 1.1 hologram meetings on any articles on under age drinking Guinness 4.10% 2.3 1.2 which the Company may communicate in its # Strongbow 4.50% 2.6 1.3 International passport in-house newsletter, security and licensing # UK photograph driving licence newsletter or brand newsletters, or through communication from line management. Wine ! If a guest does not have identification, suggest they return with some and they will Last year, more than 3,000 members of our ABV% Units/ Units/ Units/ be served when they do retail staff completed the British Institute of 175ml 250ml 75cl Innkeeping's (BII) 'National Certificate for ! Be polite and tactful, but firm, when asking 9.00% 1.6 2.3 6.8 Personal Licence Holders', which is the for identification. Do not antagonise the 9.50% 1.7 2.4 7.1 recognised national qualification in the licensed situation if a guest becomes aggressive 10.00% 1.8 2.5 7.5 trade. and/or refuses to leave. Inform a member of 10.50% 1.8 2.6 7.9 management Mitchells & Butlers is recognised by the BII as 11.00% 1.9 2.8 8.3 a leading provider of training and is licensed ! It is best practice for staff to record instances 11.50% 2.0 2.9 8.6 accordingly to deliver the training in-house. where service has been refused for whatever 12.00% 2.1 3.0 9.0 reason Our retail staff can easily access information 12.50% 2.2 3.1 9.4 about units of alcohol and alcohol by volume 13.00% 2.3 3.3 9.8 for popular drinks brands in order to provide 13.50% 2.4 3.4 10.1 that information to guests. 14.00% 2.5 3.5 10.5 Individuals have a degree of personal 14.50% 2.5 3.6 10.9 III.Alcohol & Social responsibility – Staff Training responsibility for the amount of alcohol they With over 44,000 retail staff nationally, Mitchells consume. Our employees cannot offer advice to & Butlers is committed to comprehensive customers, for example, about the Government's Spirits training and development programmes. Sensible Drinking Message. Brand ABV% Single Double (25ml) (50ml) Baileys 17.00% 0.4 0.9 Malibu 21.00% 0.5 1.1 Pimms 25.00% 0.6 1.3 Southern Comfort 35.00% 0.9 1.8 Smirnoff Red 37.50% 0.9 1.9 Smirnoff Black 40.00% 1.0 2.0 Bacardi 37.50% 0.9 1.9 Gordons 37.50% 0.9 1.9 Others 40.00% 1.0 2.0

A “unit” is equivalent to 10ml of pure alcohol To calculate units: %ABV x Vol. in ml / 10 Mitchells & Butlers plc 27 Fleet Street Alcohol and Social Birmingham B3 1JP Tel: +44 (0) 870 609 3000 Fax: +44 (0) 121 233 2246 www.mbplc.com/socialresponsibility Responsibility Policy