SUPPLIER CODE OF CONDUCT Philip Morris USA U.S. Smokeless Tobacco Company John Middleton Ste. Michelle Wine Estates Philip Morris Capital Corporation Nu Mark
Our companies are committed to responsibly providing adult tobacco and wine consumers with superior branded products. It is important that our Suppliers understand that we are concerned not only with business results but with how those results are achieved. We develop and maintain business relationships with Suppliers who share our commitment to: Conduct business in a responsible manner in compliance with applicable laws Respect the rights of workers Comply with applicable environmental laws and regulations and aim to reduce the environmental impact of their activities Implement management and monitoring practices to ensure compliance with contracts and applicable laws Respect for people is fundamental to the way we conduct business. Our expectations for our Suppliers are guided by the Universal Declaration of Human Rights and the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work. Our companies take a risk-based approach to monitoring and assessing Supplier compliance with our contracts and this Code. We believe Suppliers share this responsibility, should work cooperatively with us and endeavor to have systems and personnel in place to monitor compliance and drive continuous improvement. Altria s Supplier Code of Conduct 2
At the Altria family of companies, we believe in operating with integrity, trust, and respect. These values guide our behavior as we pursue our mission and our business strategies. Altria s Supplier Code of Conduct builds upon this strong foundation. Application The Supplier Code applies to all Suppliers that provide goods and services to the Altria family of companies. We expect our Suppliers to hold their supply chain, including subcontractors, to the same standards contained in this Supplier Code. Supplemental guidelines for select Suppliers, such as those covered by Altria s Tobacco Good Agricultural Practices Program guidelines or the Electronics Industry Citizenship Coalition (EICC ) Code of Conduct, may also apply. The Supplier Code provides guidelines for business conduct but does not replace the specific requirements in supplier contracts. Suppliers must always comply with contractual requirements. The Supplier Code does not alter contractual terms or constitute express or implied contractual obligations or contracts of employment. Laws and Regulations Suppliers must comply with all applicable federal, state, local, and foreign laws. Suppliers with operations outside the United States must also comply with the applicable laws in the countries in which they operate. If the standards or requirements set forth in this Code or in the contract are greater than applicable law, then the Supplier shall follow the higher standard. Fair Employment and Workplace Conduct HARASSMENT, ABUSE, AND DISCRIMINATION Suppliers shall promote a work environment free from verbal, physical, or mental abuse, threats, violence, or any form of harassment during employment or recruitment. Employees shall not be subject to unlawful discrimination. Employees shall not be subject to discrimination based on, but not limited to, the following: race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, or marital status. CHILD LABOR AND YOUNG WORKERS Suppliers must comply with the minimum age requirements as prescribed by applicable laws and regulations. Suppliers must adhere to our contracts or other applicable supplemental guidelines which may provide standards at a higher level. FORCED OR COMPULSORY LABOR Suppliers must not use forced or compulsory labor or engage in the trafficking of persons. WAGES, BENEFITS, AND WORKING HOURS Suppliers must comply with all applicable laws governing wage and working hour requirements, including compensation, benefits, and overtime. HIRING AND TERMINATION Suppliers must comply with applicable laws governing eligibility for employment, recruitment, and termination. FREEDOM OF ASSOCIATION Suppliers are encouraged to respect legal rights of employees to join or not to join any lawful association without fear of reprisal or intimidation. Altria s Supplier Code of Conduct 3
We encourage Suppliers to take into account the environmental impact in business decision-making and consider opportunities for conservation of natural resources, recycling, reuse, source reduction, and pollution prevention and control. Safety, Health, and Environmental SAFETY AND HEALTH Suppliers must comply with applicable safety and health laws and regulations. Altria and its companies strive for a workplace culture in which each employee works toward the goal of an injury-free career. Our companies are committed to the prevention of workplace injuries and illnesses, and to compliance with applicable laws and company policies related to employee safety and health. Suppliers must comply with applicable safety and health laws and regulations. Suppliers shall assure safe and healthy work places to reduce the risk of accidents, injuries, and exposure. THE ENVIRONMENT Suppliers must comply with applicable environmental laws and regulations. Altria and its companies are also committed to complying with applicable environmental regulations, reducing the environmental impact of its businesses, and promoting the sustainability of the natural resources on which we depend. We encourage Suppliers to take into account the environmental impact in business decision-making and consider opportunities for conservation of natural resources, recycling, reuse, source reduction, and pollution prevention and control. We encourage Suppliers to implement and have in place a performance monitoring program to account for aspects of their safety, health, and environmental programs. Altria s Supplier Code of Conduct 4
Business Ethics and Compliance Honesty, integrity, and transparency in business operations provide the foundation for our business relationships. Suppliers shall commit to the highest standards of ethical conduct and business practices. SECURITIES AND INSIDER TRADING LAWS Suppliers may learn of material nonpublic information during the course of their work for us. They may not use or share that information to trade or enable others to trade in the securities of Altria or any other company. ILLEGAL PAYMENTS, CORRUPTION, AND BRIBES Suppliers must not engage in illegal payments or corruption, including extortion, fraud, embezzlement, bribery, and kickbacks. Suppliers must comply with all applicable prohibitions and laws, including the Foreign Corrupt Practices Act and any applicable equivalent non-u.s. law. PROHIBITED PERSONS Suppliers must ensure that neither they nor their officers nor directors nor owners appear on any applicable sanctions list. Some examples may include, but are not limited to, the following: Specially Designated Nationals (SDN) and Other Blocked Persons list, the Sanctions Programs list, and the non-sdn Entities list, all maintained by the U.S. Department of Treasury, and the Denied Persons list maintained by the Bureau of Industry and Security. GIFTS Our policies place significant restrictions on the types of gifts and entertainment that our employees are permitted to accept. Suppliers must not offer any gift or entertainment to our employees that could be construed as an attempt to secure favorable treatment. Cash or cash equivalents (e.g., gift certificates) as gifts to our employees are not allowed. Suppliers must not provide any entertainment or gifts at all to any government official for or on behalf of an Altria company. Similarly, Suppliers must not make any direct or indirect political contribution or expenditure for or on behalf of an Altria company. ANTITRUST AND COMPETITION LAWS Suppliers must uphold applicable standards of fair business, advertising, and competition. Suppliers must not enter into agreements or actions that illegally restrain trade or restrict competition. Suppliers must not offer our employees any confidential information about a competitor of an Altria company. RECORDS MANAGEMENT Suppliers must maintain the confidentiality of trade secrets and other proprietary information. Suppliers must also preserve and/or dispose of Altria company records in compliance with their contractual obligations. DATA PRIVACY AND INFORMATION SECURITY Suppliers must comply with all applicable data privacy and information security laws and regulatory requirements regarding the collection, use, maintenance, transfer, sharing, disclosure, and disposal of personal and/or confidential information. Suppliers must also protect the personal and/ or confidential information they maintain on behalf of an Altria company from unauthorized access, destruction, use, modification, and disclosure. In addition, Suppliers must comply with other contractual obligations related to data privacy and information security. PROTECTION OF IDENTITY AND NON-RETALIATION Suppliers shall ensure confidentiality, anonymity, and protection from retaliation of any employee, who, in good faith, raises a concern or reports suspected misconduct, unless prohibited by law. FISCAL INTEGRITY Suppliers must maintain accurate books and records in compliance with all applicable laws, regulations, and contractual obligations. INTELLECTUAL PROPERTY Suppliers must respect and protect the intellectual property rights of each of the Altria companies and other persons and/or entities. SOURCING OF RAW MATERIALS Suppliers shall exercise due diligence, as applicable, on the sourcing of conflict minerals (tantalum, tin, tungsten, and gold) and perform a reasonable country of origin inquiry with respect to such conflict minerals, including requiring its suppliers and sub-suppliers to engage in a similar due diligence. Altria s Supplier Code of Conduct 5
Our Suppliers diversity contributes to our companies success. Our companies are committed to using a diverse base of Suppliers within our supply chain, including minority, women, LGBT, and veteran-owned businesses. Supplier Diversity and Inclusion Our Suppliers diversity contributes to our companies success. Our companies are committed to using a diverse base of Suppliers within our supply chain, including minority, women, LGBT, and veteran-owned businesses. Suppliers are encouraged to develop mutually beneficial and successful relationships with diverse Suppliers by including them in the supplier selection process and to support local, regional, and national organizations that work to increase procurement and business opportunities for minority, women, LGBT, and veteran-owned businesses. We also encourage Suppliers to set annual goals and develop metrics to track spending with diverse Suppliers. Altria s Supplier Code of Conduct 6
Monitoring and Assessments Suppliers are encouraged to review compliance on a periodic basis and designate personnel who shall be responsible for monitoring compliance with contractual obligations and this Supplier Code. Altria companies and appropriate functions may conduct periodic supplier performance reviews, assessments, and on-site visits. Falsification of records or misrepresentation of conditions or practices in Supplier s operations is unacceptable. When we learn of non-compliance issues, we communicate them to Suppliers. Suppliers shall take corrective actions to address non-compliance issues and keep us informed of their remediation efforts. We reserve any and all contractual rights to halt business with Suppliers if remediation or abatement efforts to achieve compliance are not effective or timely. We take a continuous improvement approach and work with Suppliers to improve their practices. Altria s Supplier Code of Conduct 7
www.altria.com Altria Group, Inc. 2017