Think Wisely Drink Wisely

HEAVEN HILL CORPORATE/SOCIAL RESPONSIBILITY STATEMENT

Adopted by the Board of Directors January, 2006.

Introduction

Since 1934, Heaven Hill Distilleries has been a leading producer of beverage alcohol. Our company embraces independence, quality and tradition as hallmarks of our reputation. Since our founding, Heaven Hill has engendered an attitude of responsible consumption and social responsibility among our employees, agents and partners with regard to promoting and marketing our broad portfolio of brands around the world.

This is Heaven Hill’s Corporate/Social Responsibility Statement (CSRS). It codifies in formally recognized policy the set of beliefs we have followed in spirit since 1934.

Core Beliefs

  • Heaven Hill only markets products to adults of legal drinking age.
  • Heaven Hill recognizes that consumption of beverage alcohol by minors is dangerous and unhealthy.
  • Heaven Hill advocates a strict stance on responsible consumption of beverage alcohol. This includes acknowledging the harm of excessive or irresponsible consumption by adults.
  • Heaven Hill is committed to being a responsible member of the beverage alcohol community by monitoring all marketing, promotions and communications for generally acceptable messages and practices.

Overview

Beverage alcohol is an important element in communities and social relationships throughout the world. When consumed responsibly, our products contribute to memorable experiences and social activities. As a result, it is important to promote our products in a manner consistent with responsible consumption.

Compliance

Heaven Hill will comply with applicable government and industry standards regarding marketing and communications domestically and internationally. In many cases, relevant standards are established by a trade organization representing the interests of the industry. However, when regulations in localities or cultures exceed those outlined in this CSRS in stringency or scope, all Heaven Hill employees, representatives and agents will abide by those regulations. Conversely, where standards for the beverage alcohol industry have not been established, this CSRS will act as the standard.

While this CSRS cannot address every present and future circumstance, Heaven Hill will abide by it in spirit where applicable. All employees, representatives and agents of Heaven Hill are expected to comply with both the letter and the spirit of the CSRS.

In the case of the U.S., Heaven Hill recognizes the Distilled Spirits Council of the United States (DISCUS) “Code of Responsible Practices for Beverage Alcohol Advertising and Marketing,” adopted in October 2003, as the “industry standard.” The DISCUS Code represents a common standard for the U.S. beverage alcohol industry to respect.

Scope

This CSRS applies to all corporate and brand marketing, advertising, sales and communication materials, packaging and activities for consumer and trade purposes. It is a guideline for all employees, representatives and agencies of Heaven Hill to follow in promoting our products.

Underage Consumption

We will seek to discourage underage drinking, including through observing the following principles:

  • Our advertising and marketing will never show consumption by minors or be intentionally aimed to appeal to minors.
  • Models for all advertising and marketing materials must be and look to be a minimum of 25 years old.
  • Our advertising and marketing programs will only utilize broadcast, cable, digital and print media outlets with audiences made up of more than 70% adults 21 or older, as determined in accordance with the industry standard.
  • Our internet sites will require confirmation of age for entry when promoting specific brands. Users/visitors opting out or not meeting age verification requirements will be directed to The Century Council website.
  • Clothing, games, publications, media and novelties used in the marketing and advertising programs of our brands will never intentionally be aimed to appeal to minors and we will not license our brands for such materials.
  • We will not target marketing activities at any persons under the age of 21 regardless of legal purchase age in their locality.
  • Our advertising and marketing will not be portray alcohol consumption in a manner associated with the attainment of adulthood or the “rite of passage” to adulthood.

Responsible Advertising

We will seek to discourage irresponsible drinking, including through observing the following principles:

  • Our advertising and marketing materials will never depict irresponsible, dangerous or excessive consumption of beverage alcohol in any fashion.
  • Our advertising and marketing materials will carry messages encouraging responsible consumption in line with the style of the product or brand message.
  • Our depictions of consumption will be responsible and reasonable and be consistent with the positive role beverage alcohol can play in social engagements.
  • Our advertising and marketing materials will make no claim to enhanced professional, social, educational or athletic status as a byproduct of consumption.
  • We will not depict alcohol consumption as aiding in sexual, mental or physical performance or proficiency.
  • Our advertising and marketing materials will not communicate a health, healing or therapeutic benefit as a byproduct of consumption.
  • Our advertising and marketing will not depict graphic or gratuitous nudity, overt sexual activity, promiscuity or sexually lewd or indecent images or language.
  • Our advertising and marketing will not employ religious themes or symbols.

Promotions

In the conduct of on-site and other promotional events,

  • Employees, representatives and agents of Heaven Hill promoting products on-premise will be of legal purchase age.
  • Our employees, representatives and agents promoting products on-premise will attempt to encourage safe and responsible consumption by adults.
  • Our employees, representatives and agents will only offer sampling in accordance with local regulations at locations hosting promotional events.
  • Employees, representatives and agents of Heaven Hill will discourage and use available measures to prevent underage consumption.

Social Responsibility

Heaven Hill will not use depictions of violence, abuse, illegal activities or dangerous behavior in association with any marketing or advertising programs.

We will monitor all advertising and marketing messages to ensure sensitivity to foreign and domestic considerations. While defining “offensive” in other cultures is often challenging, we will make reasonable efforts to abide by generally accepted standards of decency.

Drinking & Driving

We will seek to discourage drinking and driving, including through observing the following principles:

  • Drinking and driving is illegal, always dangerous and often deadly.
  • Marketing and advertising should never condone operation of machinery, driving or activities requiring heavy concentration before or while consuming beverage alcohol.

Alcohol Content

The alcohol content of our products should be clearly and plainly visible on their labeling.

Oversight

Marketing Compliance

Review of marketing materials for compliance must be completed upon final approval by responsible marketing personnel. Compliance with this CSRS is mandatory and will be monitored continually.

Our advertising and public relations agencies must observe this CSRS throughout the creative process.

Internal Marketing Monitor

As an additional safeguard, Heaven Hill will maintain a system for unbiased review of marketing materials by a senior non-marketing executive designated as the Internal Marketing Monitor.

The Internal Marketing Monitor will be appointed by the President to review marketing materials on a semi-annual basis. The post-completion review will take place after the annual sales meeting, which offers a full accounting of upcoming calendar year marketing activities. The meeting historically takes place in December of each year. An interim review of marketing materials will be completed upon the close of the calendar second quarter. The Internal Marketing Monitor will issue a report regarding compliance concerns or approval based on CSRS requirements within thirty days of each review date.

The Internal Marketing Monitor’s recommendations will be directed to the head of the Marketing Department for proper disposition and a further report to the President.

The Internal Marketing Monitor is not responsible for auditing promotional or on-premise activities.

Alleged Code Violation Complaint Procedures

Any complaint received regarding an alleged code violation of this CSRS will be directed to the Corporate Communications Department for review and investigation using marketing strategy personnel and resources responsible for development of concept. Responses would include a summation of the responsible materials with a determination of remedial action (continued use, modification or discontinuation). Within one month, the complainant will receive a written response from Heaven Hill Corporate Communications. The complainant will be invited to respond to Heaven Hill’s actions by accepting the determination or requesting further comment or external review.

Upon request for external review, Heaven Hill will then submit, under the federal Alcohol and Tobacco Tax and Trade Bureau (TTB) guidelines for “Alcohol Beverage Advertising Program”, all due diligence relative to the inquiry (as outlined in the TTB Industry Circular 2004-6). Further, Heaven Hill will continue voluntarily to submit advertising to the “pre-clearance review program” where necessary.

In addition to the internal and alleged code violation process, Heaven Hill will continue to respond and cooperate with the DISCUS code and TTB initiated investigations, as needed. The company maintains an ongoing dialogue with the DISCUS Code Review Board as a third party review mechanism for the beverage alcohol industry.

Heaven Hill bases its reviews on the DISCUS code and TTB regulations.

Communicating Complaint Procedure Protocol

Heaven Hill provides the federally-required “mandatories,” which provide mailing addresses on advertising and marketing materials, along with a “Social Responsibility” section on the corporate website for communication of complaint procedure protocol. Branded websites offer “Contact Us” e-mail and federally required “mandatories” for direct correspondence. All branded “Contact Us” e-mails are handled under the Alleged Code Violation Complaint Procedures.