GLOBAL POLICY ON ALCOHOL RESPONSIBILITY

American Cowboy Whiskey Company® recognizes that our Company is in the eyes of the beverage community that innovates, markets and sells distilled adult alcoholic beverages, and we acknowledge that our growth into alcohol brands comes with significant added responsibilities. We note that different beverage categories require distinct approaches, and we are committed to use our best endeavors to ensure the avoidance of confusion between our alcohol brand and others. Alcohol in moderation can be part of enjoyable occasions and our brand is made to be enjoyed responsibly by people over the legal purchasing age (LPA) for alcohol. Nonetheless we recognize that harmful drinking creates problems and our evolution in alcohol brands as part of our portfolio is directly grounded in responsibility. American Cowboy Whiskey Company® Policy for Alcohol Responsibility is the overall architecture of our approach. It is global in its application and covers all our brands that contain alcohol, use an alcohol trading name category. Compliance with its provisions is mandatory for our employees. There are four specific components to our policy:

1. Responsibly marketing our alcohol brands (underpinning this section is a detailed policy, see below).
2. Supporting local partnerships and communications programs to help reduce and prevent the harmful use of alcohol.
3. Providing information to enable people to make informed choices.
4. Enabling our employees and partners to be ambassadors for responsible consumption.

We support the United Nations’ Sustainable Development Goal (SDG) 3 to ensure healthy lives and promote well-being for all and will take action to help ensure our alcohol beverages are consumed responsibly.
1. Responsible marketing Responsible marketing is foundational to American Cowboy Whiskey Company® and is a critical aspect of building and maintaining our reputation, brand and business. American Cowboy Whiskey Company® Responsible Alcohol Marketing Policy is a policy that supports the above-mentioned architecture by providing detailed guidance on marketing. The Responsible Alcohol Marketing Policy extends to our global operations, including our bottling and other partners, such as agencies who market and sell our beverages and interact with our customers. Our contracts with advertising agencies, in a market where we have an alcohol brand, will include a clause requiring compliance. Through our Responsible Alcohol Marketing Policy, we aim to:

• Ensure that our marketing does not target or appeal to people under the LPA.
• Champion responsible consumption.

The Responsible Alcohol Marketing Policy is outlined in the latter section of this page.
2. Local partnerships and communications programs We will develop local partnerships and/or communications programs to help reduce and prevent the harmful use of alcohol in line with the goals established by leading health authorities. The purpose of the local industry partnerships and/or communications programs are to: discourage underage drinking; combat drunk driving; discourage drinking by pregnant or breastfeeding women; or raise awareness for responsible consumption. In developing the local partnerships and/or communications programs, we will work in close collaboration with local experts or those aligned with best practice.
3. Information and transparency We are committed to helping give people information to make responsible drinking choices. American Cowboy Whiskey Company® where legally allowed, the packaging of our alcohol brand, consumer campaigns and marketing assets will include at least one message related to responsible consumption, such as ‘Please Drink Responsibly’, as outlined in our Responsible Alcohol Marketing Policy. Where legally allowed, we may also include nutritional information panels on the back of pack. We believe it is important that people are well-informed about alcohol, our products and how they can be enjoyed responsibly.
4. Guidelines for our employees and partners as role models We aim to ensure our employees and partners are ambassadors for responsible consumption. Setting an example for responsible consumption means that if our employees or partner associates wish to enjoy an alcohol brand, that they consume responsibly and encourage others to do so. We require our employees and partner associates to obey local laws and Company policies, including our Code of Business Conduct. This includes ensuring all employees and partner associates are treated with respect and in accordance with its provisions. Alcohol consumption is not permitted during working hours (there are limited scenarios where this is permitted, such as testing products or at company events). All conduct must be in accordance with our Company policies and codes. It is important that our employees and partner associates are ambassadors for responsible consumption.

THE AMERICAN COWBOY WHISKEY COMPANY
GLOBAL RESPONSIBLE ALCOHOL MARKETING POLICY

The first part of our Policy on Alcohol Responsibility relates to responsible marketing, it is underpinned by the Responsible Alcohol Marketing Policy. Responsible marketing is foundational to The American Cowboy Whiskey Company® and a critical aspect of building and maintaining our reputation, brand and business. Our Responsible Alcohol Marketing Policy extends to our global operations, including our bottling and other partners such as agencies who market and sell our beverages and interact with our customers. Our contracts with advertising agencies, in a market where we have an alcohol brand, will include a clause requiring compliance. Through this policy we aim to ensure all our activities depict and encourage only responsible moderate drinking and never target those who are younger than the LPA for alcohol.
The policy applies to, but is not limited to, the following:

• Consumer advertising, including TV, radio, print, out-of-home, cinema.
• Direct marketing, including text messaging and email.
• Digital media, including websites, paid search, social media, in-game advertising, user-generated content on Company sites or third-party platforms.
• Point-of-sale materials and sales materials.
• Packaging and labeling.
• Sponsorships and events.
• Promotions, cross-promotions, and experiential marketing programs.
• Gifts and branded merchandise, including games, toys, and equipment.
• Sampling and multi-buys.
• Product placement through sports, events, celebrities, or influencers.
• Market research.
• Consumer, trade and brand public relations activities (excluding corporate communications).

There are eight principles that guide our marketing.

1. Comply with laws and codes
1. • These principles provide a clear global baseline for our engagement.
   • However, our marketing must comply with both the letter and spirit of all applicable laws and codes in the jurisdiction in which it appears. If local requirements are more stringent than these principles, then our marketing must abide by those additional requirements.
2. Only appeal to people above the Legal Purchase Age (LPA)
1. • Our marketing will never target people under the LPA for alcohol. If the local LPA is below 18 years or absent, then we will use 18 as a minimum.
   • We will not use images of people in our marketing, or influencers, under the age of 25 and we will comply with the World Federation of Advertisers Responsible Marketing Pact which bans a list of creative features known to ‘primarily appeal to minors’.
   • With regards to media, including shows, print media, movies, games and social media, we will not advertise when more than 20% of the audience is under the LPA. Therefore, acceptable media must have 80% or more of the audience over the LPA.
   • We will ensure we do not place advertising on any outdoor stationary location which is less than 200 meters from a primary or secondary school. If local laws or regulations exist in a local market stipulating an alternate distance, we will defer to those local laws/regulations.
   • For digital and e-commerce content, we will use a range of available technology to prevent access to those younger than the LPA, including:
   • Age-gating: an age-affirmation mechanism to check the user is over the LPA. If a person is below the LPA they will be locked out or directed to a website in that country focused on responsible consumption.
   • Age-based targeting: digitally promoted content must have an age-based target above the LPA for the country.
   • Digital or social media platform terms and conditions: each online brand channel or ad placement must be established according to the user terms governing alcohol advertising on that platform (e.g. age-based targeting, warnings).
   • Forward advance notices: We will clearly state in a visible location (homepage, footer, bio etc.) that “Content for [LPA]+. Do not share with anyone under the legal purchasing age.”
   • Nanny tags: which describe the content in a manner that permits their spotting by parental control software.
   • Opt-out mechanisms: appropriate measures to be in place to allow people to opt-out of direct marketing lists or advertising of alcohol products.
   • Responsible drinking messages: digital platforms must include a clearly visible responsible drinking message (see examples below).
   • Transparency: communications will be badged so users know these are advertiser-owned pages (and therefore commercial) and not user-generated content messages.
   • User-generated content checks: content posted on Company-controlled digital platforms will be moderated on a regular basis to ensure Policy compliance. Comments which condone dangerous or excessive drinking will not be permitted.
   • We will not engage with or sponsor a celebrity/influencer whose audience is primarily composed of people under the LPA or primarily appealing to people under the LPA. Celebrities and influencers will be made aware of our Responsible Alcohol Marketing Policy and we will require that any sponsored social media posts or content comply with this policy.
   • Branded sponsorships of sporting and entertainment events will only occur where most of the audience is reasonably expected to be over the LPA.
   • We will not use people involved in the sampling or promotion of our alcohol brands who are under the LPA. We will only promote and sample at events with dedicated space for people over the LPA and where most of the event audience is reasonably expected to be over the LPA.
   • We will not use our alcohol brands or logos on merchandise such as toys, children’s games, children’s clothing, video game consoles and related gaming equipment and devices.
3. Only depict responsible consumption
1. • Our marketing will depict and encourage only moderate and responsible consumption and will incorporate responsible drinking messages. We will never depict excessive or irresponsible consumption.
   • At least one responsible drinking message is required for all marketing, sponsorship and event assets, where legally permissible. The size and placement will depend on the context but must be clear. Responsible drinking messages are: Please drink responsibly; Don’t drink and drive; For people over the age of [LPA] only; or Pregnant women should not drink alcohol. Alternatively, markets may be required to place government-mandated health messages and/or warnings.
   • Where legally permissible, all labels (front or back) and secondary packaging must include at least one responsible drinking message or an associated icon, as noted above.
   • At events, we will not incorporate drinking games with speed incentives or which encourage excessive consumption, and servers and sellers at events will be trained on the responsible serving and selling of alcohol. Events are encouraged to provide safe ride home or designated driver programs.
   • We will not conduct market or consumer research among people below the LPA, we will limit consumer samples to a maximum of the equivalent of two standard drinks per day and research sessions will incorporate safe ride home or designated driver programs.
4. Provide clear information on alcohol content
1. • Our packaging will clearly state the alcohol content of our products, this includes on primary and secondary packaging. This will also be mandatory on alcohol brand websites.
   • Our marketing will not present a higher alcohol strength as a reason to consume nor imply that a non-alcohol variant of an alcohol brand can be overconsumed.
5. Do not imply health benefits
1. • Our marketing will not imply any health benefits, therapeutic or dietary benefits or performance benefits from consumption.
   • We will not suggest that alcohol can prevent, treat or cure illness or that alcohol offers a remedy for personal problems such as loneliness, stress or boredom.
   • We will not portray or target pregnant women.
6. Do not encourage drink driving or other dangerous activities
1. • Our marketing will only portray drinking in safe and appropriate circumstances and never portray drinking while driving any kind of vehicle, operating machinery or other endeavors requiring alertness.
   • It is acceptable to show adults enjoying a drink after engaging in activity provided consumption is clearly after the activity has taken place.
7. Do not imply social or sexual success
1. • Our marketing will not portray or imply that drinking is necessary to obtain social or other success, nor to overcome inhibitions or to be socially accepted.
   • We will not portray or imply that drinking enhances sexual attractiveness or is a requirement for sexual success. Nor will it be associated with the attainment of adulthood or ‘rites of passage’ to adulthood. Implicit sexual activity, nudity, seduction scenarios and gender stereotyping must all be avoided.
8. Always ensure good taste and cultural sensitivity
1. • Our marketing will not portray anti-social or illegal behavior, nor be associated with tobacco or gambling.
   • We will be sensitive to local and cultural variation. We should not use themes, images, symbols or portrayals likely to be offensive, derogatory or demeaning.
   • Care must be taken in locations close to religious buildings or other places which may give rise to local sensitivities.

Compliance with this policy is global, will be taken seriously and reviewed on an ongoing basis. This may include, without limitation, randomly conducted audits by internal and/or external auditors, as well as certifications as appropriate. Compliance with all Company policies is expected, except in circumstances for example if legal differences or restrictions apply. Non-compliance with any Company policy has consequences and may result in corrective action. Drink Responsibly