Anti-Corruption Policy Our Anti-Corruption Policy is in compliance with our Code of Business Conduct and covers the following important topics: Gifts and corporate hospitality Acceptance of gifts and hospitality Touch Point vendors Charitable contributions Political contributions Facilitation payments Record keeping

Gifts and Corporate Hospitality AB InBev and its employees/directors are forbidden to provide gifts, meals, entertainment and travel expenses to anyone in exchange for an improper benefit or advantage to the Company. However, if there is no improper benefit or advantage for the Company, we are allowed to provide gifts, meals, entertainment or travel expenses under specific conditions, as follows. Remember to consult the Compliance Channel in case you have questions before making a decision! .

Policy Summary: Public Officials GIFTS Limited to USD 100 per person; No more than twice per 12-month period; Spouses are not allowed to receive; Always requires Compliance Channel pre-approval. Requires Compliance Channel pre-approval when above limits. Limited to USD 200 per person; MEALS ENTERTAINMENT TRAVEL

Policy Summary: Commercial Counterparties GIFTS Limited to USD 100 per person; No more than twice per 12-month period; Spouses are not allowed to receive; Requires Compliance Channel pre-approval when above the limits. Limited to USD 200 per person; Always requires Compliance Channel pre-approval. MEALS ENTERTAINMENT TRAVEL Note that if the corporate gift/meal/entertainment/hospitality is provided to the commercial counterparty in the context of a written commercial agreement or sales incentive program, the limits and procedures are not applicable.

Gifts and Corporate Hospitality: Summary Ab InBev may not offer, promise, pay, give, or authorize an improper or unlawful payment, benefit, advantage or reward, even if doing so results in the loss of business opportunities for AB InBev. Even if there is no improper advantage or reward to the Company, you must consult the Compliance Channel to seek approval and to log the gifts according to the policies. All expenses must be supported by receipts and accurately recorded in the Company’s books and records.

Case 1: What Would You Do? Suppose we are celebrating the opening of a new plant in your Zone. We invite the mayor and other officials to join the celebrations. During that day, they visit our new facilities and attend a meeting with our Supply Director, who talks about investment plans. We offer all guests attending the event a pack of beer produced in our new plant! (valued at USD 30). After hosting the politicians, a guest list and the proposed gift is submitted to the Compliance Channel for approval. Is this correct? Yes No

Case 2: What Would You Do? Suppose you received approval from the Compliance Channel to give a pack of beer to the mayor and the other officials who attended the opening. The next step is to book the total amount as a production cost. Is this correct? Yes No

Anti-Corruption Policy Gifts and corporate hospitality Acceptance of gifts and hospitality Touch Point vendors Charitable contributions Political contributions Facilitation payments Record keeping

Acceptance of Gifts and Hospitality AB InBev employees are not allowed to accept anything of value including gifts, entertainment, travel, or meals from an actual or potential supplier, customer, Public Official or other third party. If you receive a gift in such circumstances, it should be turned over to AB InBev to be auctioned or donated. Note that employees are allowed to accept invitations to business-related conferences and networking events, including incidental meals and refreshments. Remember to consult the Compliance Channel in case you have questions before making a decision!

Case 3: What Would You Do? To thank you for conducting business with him, a supplier offers to pay for your dinner during a meeting. Can you accept? Yes No

Case 4: What Would You Do? A supplier gives Paul, an AB InBev employee, a moderately priced bottle of whiskey in appreciation for all his hard work. Can Paul accept it? Yes No

Anti-Corruption Policy Gifts and corporate hospitality Acceptance of gifts and hospitality Touch Point vendors Charitable contributions Political contributions Facilitation payments Record keeping

Touch Point Vendors: Risk of Corruption “Touch Point vendors” are certain third parties that may interact with Public Officials while providing goods or services to the Company, such as: Consultants Agents for permits Distributors Promoters Event organizers Marketing agencies Customs brokers Freight forwarders Lessors

Touch Point Vendors: Risk of Corruption Before you engage/pay a Touch Point vendor, make sure you consult the Compliance and/or Legal team! They will conduct a background check on the vendor to assess any corruption/reputational risks of retaining its services.

Working with Touch Point Vendors: Summary We cannot pay/engage a Touch Point vendor before receiving clearance from the compliance team. Make sure that all payments to Touch Point vendors are correctly booked and supported by proper documentation describing the services provided. Consult the Compliance Channel, if you have questions.

Case 5: What Would You Do? You are responsible for the environment license in your unit and a vendor is offering to help you with the procedures of the government branch responsible for granting the license. Can you retain and pay for such services? Yes No

Case 6: What Would You Do? In the same situation as mentioned before, can you pay for the services and book it as product write-off or a POC discount? Yes No

Case 7: What Would You Do? What if the unit is located in real estate that is leased to AB InBev? Do we still need to oversee the licensing process conducted by the lessor? Yes No

Anti-Corruption Policy Gifts and corporate hospitality Acceptance of gifts and hospitality Touch Point vendors Charitable contributions Political contributions Facilitation payments Record keeping

Charitable Contributions Charitable Donations: Charitable Contributions Charitable donations to public/private entities made (such as: municipalities, police forces, etc.) at the request of a Public Official must always be submitted for approval through the Compliance Channel and must also: Not be paid in cash; Not be made as part of an exchange of favors with a Public Official; Not be paid to a private account or individual, or to a for-profit organization; Not amount to a political contribution Be transparent regarding the identity of the recipient, the amount and the purpose for which it is intended.

Case 8: What Would You Do? If a public school asks for a soda donation for a Christmas party, what should you do? Provide it in cash and ask for reimbursement Submit for approval through the Compliance Channel

Anti-Corruption Policy Gifts and corporate hospitality Acceptance of gifts and hospitality Touch Point vendors Charitable contributions Political contributions Facilitation payments Record keeping

Anti-Corruption Policy Political contributions can only be made if approved by the Board of Directors and in accordance with local legislation. Remember to consult the Compliance Channel in case you have questions before making a decision!

Case 9: What Would You Do? If a political candidate organizes a fundraiser for his/her campaign, can we donate free products for the event? Yes No

Anti-Corruption Policy Gifts and corporate hospitality Acceptance of gifts and hospitality Touch Point vendors Charitable contributions Political contributions Facilitation payments Record keeping

Anti-Corruption Policy Facilitation or grease payments are usually small payments to a low-level government employee to expedite or secure performance of a routine, non-discretionary governmental action, such as obtaining utility services or clearing customs. They are unlawful in most countries and are strictly prohibited under AB InBev’s Anti-Corruption Policy. Remember to consult the Compliance Channel in case you have questions before making a decision!

Case 10: What Would You Do? An AB InBev employee needs to get new equipment installed quickly, but the shipment is delayed at the port. A local official offers to expedite it through customs for 5 USD. Your customs broker pays the fee and submits an invoice to AB InBev. Would it be correct to reimburse the customs broker? Yes No

Case 11: What Would You Do? An AB InBev employee needs to improve plant area security due to local criminal activity and offers some crates of beer and/or free meals at the plant to the police in exchange for stopping by at least twice per week. Is this correct? Yes No

Anti-Corruption Policy Gifts and corporate hospitality Acceptance of gifts and hospitality Touch Point vendors Charitable contributions Political contributions Facilitation payments Record keeping

Record Keeping: Guidelines We must ensure the accuracy of our books, records, inventories, expense reports, entertainment, travel and gift reports. Before making payments or offering gifts, always make sure that: they are accurately recorded in the correct package; supporting documentation, such as invoices for services provided, contracts, etc. is in place; no undisclosed or unrecorded funds or assets may be established.

Case 12: What Would You Do? If a police officer asks for a beer donation for an internal event at the force, and you get approval through the Compliance Channel, can you book it as discount to a POC owned by one of the police officer’s relatives? Yes No

THE COMPLIANCE HELPLINE

You can easily access the Helpline site from our Compliance Helpline If you witness or suspect a violation of our Code of Business Conduct, the law, or our policies – or if one is reported to you – you should act. Make a confidential report online at http://talkopenly.ab-inbev.com or +44 124 966 1781 The online reporting site and hotline are operated by an independent company available 24 hours a day 7 days a week. If you wish, your report can be made anonymously. You can easily access the Helpline site from our Compliance Channel.

Case 13: What Would You Do? While reviewing some financial files, David finds irregularities in several payroll records. When looking at previous records, he notices a pattern of irregularities that started a few months ago. Upon further investigation David finds that the irregularities involve direct colleagues with whom he has a good working relationship. What should David do? Nothing Report the situation via Helpline

Thank you for taking the time to attend this Code of Conduct and Anti-Corruption training! If you have any questions, please contact us via the Compliance Channel: http://compliancechannelglobal.ab-inbev.com/

PLEASE REMEMBER THAT INTEGRITY IS THE FOUNDATION OF AB INBEV’S LONG-TERM SUCCESS. We are the owners of our culture and principles, and we need to protect them.