1. 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

2. 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! .

3. 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

4. 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.

5. 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.

6. 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

7. 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

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

9. 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!

10. 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

11. 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

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

13. 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

14. 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.

15. 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.

16. 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

17. 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

18. 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

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

20. 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.

21. 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

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

23. 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!

24. 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

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

26. 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!

27. 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

28. 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

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

30. 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.

31. 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

32. THE COMPLIANCE
HELPLINE

33. 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 or
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.

34. 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

35. 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:

36. 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.