Home Introduction Your Personal Responsibility KDP CODE OF CONDUCT Speaking Up! Our Commitments Our Workplace Our Customers, Suppliers & Competitors Our Investors Our Consumers Our Communities Our Reputation A MESSAGE FROM ROBERT J. GAMGORT Executive Chairman & CEO KDP Team: At Keurig Dr Pepper, we believe in doing business with a purpose and we accomplish this by deeply embedding our values – Team First, Deliver Big, Think Bold, Be Fearless and Fair – ethics and integrity into all that we do. Instead of choosing what is easy or expedient, we fix our eyes on the future, and we consider the long-term effects of our decisions. Importantly, we consider the impact of our decisions on our company’s performance, our communities, and the environment. It’s up to all of us to live our values, to always be truthful, and to treat each other with respect. Our Code of Conduct explains how to integrate our purpose, mission, and values into your daily decisions. It demonstrates our company’s commitment to our stakeholders, including you, our employees, to be responsible corporate citizens and good business partners. It is a common reference that we can all learn from and live by in our journey to excellence, by embracing the understanding that our personal decisions can have far-reaching consequences for all of our stakeholders. Together with individual responsibility and good judgment, our Code guides us in making the right decisions about how we work and what we do. Thank you for your dedication to KDP and your commitment to upholding the standards set forth in our Code of Conduct. Join us as we go forth with excellence, to use the power of a thriving, innovative, well-run business to make the world a better place. Best Regards, 2 Bob 2 Your Personal Our Our Our Customers, Our Our Our Our Home Introduction Speaking Up! Suppliers & Responsibility Commitments Workplace Competitors Investors Consumers Communities Reputation 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 YOUR PERSONAL RESPONSIBILITY Our Code is about doing the right thing at all times. COMPLIANCE ROADMAP FOR MAKING Compliance starts with you, and you are responsible for: ETHICAL DECISIONS • Understanding and complying with our Code and We expect you to use good judgment AT THE HEART OF EVERY related policies. and common sense to comply with SUCCESSFUL TEAM IS • Familiarizing yourself with and following the laws and the letter and spirit of our Code and THE BELIEF THAT WE regulations that apply to our business and your job. our other policies and avoid even the CAN COUNT ON EACH • Acting with the highest standards of ethics and integrity. appearance of improper behavior. OTHER TO OPERATE IN A • Reporting violations and misconduct. When an issue is not directly RESPONSIBLE MANNER, addressed, you should use the Code ACT IN THE BEST INTEREST Failure to comply may lead to disciplinary action, including as a roadmap for making ethical OF THE TEAM, AND MAKE termination for cause. decisions. In all cases, ask yourself: APPROPRIATE DECISIONS FOR OURSELVES AND • Is this compliant with our policies ON BEHALF OF THE Thank you for your efforts and/or well within the spirit of our COMPANY. to ensure Keurig Dr Pepper policies? continues to be recognized • What might the impact of my action by our employees, consumers, be? Could it hurt the company’s customers, vendors, and reputation or my professional shareholders as an ethical reputation? company with great brands • Would I be comfortable telling my and great people. manager about my decision, or seeing my decision reported in the news media? If there is still any doubt, see Key Questions for whom to ask. 3 Your Personal Our Our Our Customers, Our Our Our Our Home Introduction Speaking Up! Suppliers & Responsibility Commitments Workplace Competitors Investors Consumers Communities Reputation 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 KEY QUESTIONS TO WHOM DOES THE CODE APPLY? WHO DO I ASK IF I HAVE A QUESTION? Our Code applies to all employees, officers, and directors If you have questions about how to interpret this Code, (“you”) of Keurig Dr Pepper Inc. and its subsidiaries (“compa- you may ask through our hotline reporting channels. Please ny” or “we”) in all of our locations. We also expect our con- note that compliance responsibility ultimately rests with you. sultants, vendors, contractors, and other third parties with whom we do business to abide by the portions of our Code WHO REVIEWS AND APPROVES THE CODE? that are applicable to our relationship. Note that in certain The board of directors reviews and approves our Code of Conduct. cases, the policies may apply to your family members, and Other policies may be reviewed and approved by the board and/or persons with whom you live. other senior management. The audit committee of the board of directors and the general counsel’s office monitor compliance with DOES THIS CODE COVER ALL OF this Code and take appropriate actions to promote accountability MY OBLIGATIONS? and address misconduct. Please note that we reserve the right to In this Code, we provide guidance, but cannot list all amend or modify this Code or other referenced policies at any time. activities or behaviors that may be inappropriate. This guidance is not intended to cover all potential situations, WHO MUST APPROVE A WAIVER? and the examples provided here do not limit the generality If circumstances are unclear and you believe that a waiver of of the Code or other policies. any provision of this Code is warranted, you must disclose all relevant facts and make such request through the general counsel’s DO OTHER POLICIES APPLY? office. Waivers for employees, other than executive officers and the Yes. Our Code is a starting point for understanding your principal accounting officer or controller, may only be made by the obligations. Other policies apply, some of which are general counsel. Waivers for executive officers and the principal referenced in this Code. These other related policies may be accounting officer or controller shall only be made by either the provided to you or are available to you online. audit committee of the board of directors or the board of directors. Waivers for a board member shall be made only by the board of directors. 4 Your Personal Our Our Our Customers, Our Our Our Our Home Introduction Speaking Up! Suppliers & Responsibility Commitments Workplace Competitors Investors Consumers Communities Reputation 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 A GOOD FAITH REPORT MEANS THAT YOU HAVE PROVIDED ALL OF THE SPEAKING UP! INFORMATION YOU HAVE AND BELIEVE IT TO BE TRUE. We value openness and honesty. WE PROHIBIT RETALIATION AGAINST ANYONE WHO MAKES A REPORT IN GOOD FAITH. REPORTING INVESTIGATION If you are aware of a breach or a potential breach of this Code, We will review and investigate reports promptly, thoroughly laws, or KDP policies, you have a duty to report it. To assist us in and fairly, taking appropriate action whenever necessary. You investigating, you are encouraged to provide all of the information are expected to participate in an investigation when asked. you are comfortable with providing. Our Speaking Up policy provides Investigations are conducted without regard to a suspected a way for you to report anonymously, if you choose, and without wrongdoer’s length of service, position/title, or relationship to concern for retaliation. You may: the company. If you are not satisfied with our actions taken in Write to KDP at the following address: response, you may report the matter to the chairman of the audit committee of the board of directors at the company Keurig Dr Pepper Inc. address provided. 5301 Legacy Drive Plano, TX 75024 CONFIDENTIALITY Attn: General Counsel Every reasonable effort will be made to maintain the You can submit reports 24 hours a day, 365 days a year. confidentiality of information reported. An investigation will not Submit on the web at: be disclosed or discussed other than with those with a legitimate KDP.alertline.com need to know. We reserve the right in our sole discretion to You may disclose any information obtained during an investigation As an alternative you may call: make such reports to any third party, including any federal or state agency. From the U.S. and Canada dial 800.349.4248. anonymously if you choose. From outside of the U.S. and Canada, dial your RETALIATION/OBSTRUCTION country’s AT&T direct Access code available from We will not tolerate retaliation in any form against any person https://www.business.att.com/collateral/access.html. for reports made in good faith. Any retaliation or attempt to Then, once prompted, dial 800.349.4248. deter or obstruct an employee from providing such information or participating in an investigation will be treated as a serious disciplinary offense. 5 Your Personal Our Our Our Customers, Our Our Our Our Home Introduction Speaking Up! Suppliers & Responsibility Commitments Workplace Competitors Investors Consumers Communities Reputation 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 OUR COMMITMENTS Our Code of Conduct outlines the commitments we’ve made to our stakeholders and those with whom we do business, and our expectations of our company and personnel to act in a professional, ethical, and legal manner in all their dealings. OUR CODE OUR WORKPLACE OUR INVESTORS We are committed to creating a positive and We are committed to the utmost integrity in our diverse workplace that is free from discrimination accounting and financial reporting and the manner and harassment.