1.1. The Super Bock Group Speak Up (“Policy”) aims to provide a framework and establish the regulatory standards and principles to be observed in the treatment (reporting, receipt, analysis and conclusion) of possible infractions reported by Whistleblowers, which relate to any company of the Super Bock Group (“Company”), under the terms defined in this Policy, and in accordance with the legal and regulatory provisions applicable at all times.

1.2. With the approval of this Policy, the operating model of the Whistleblowing Channel of the Super Bock Group will be updated, which aims to provide the Company with a mechanism for reporting irregular practices, through an effective, fast and suitable system for their detection, investigation and resolution, in accordance with the highest ethical principles and with a guarantee of anonymity or confidentiality, safeguard and non-retaliation in relations with the Whistleblowers, as well as complying with the standards of data protection and information security.

2.1. For the purpose of this policy, infringements are considered to be all acts or omissions, wilful or negligent, committed within the scope of professional activity, which any interested party detects, becomes aware of or has reasonable doubts about, in relation to the following matters:

1. >Harassment, discrimination and abusive behaviour;
2. >Conflict of interests and transactions with related parties;
3. >Theft and misappropriation of assets;
4. >Accounting and tax fraud;
5. >Corruption and related offences, money laundering and terrorist financing;
6. >Public procurement and contracts;
7. >Product and transport safety and compliance;
8. >Protection of the environment;
9. >Radiation protection and nuclear safety;
10. >Food safety, animal health and welfare;
11. >Public health;
12. >Competition law, protection and consumer protection;
13. >Data protection, privacy and cybersecurity;
14. >Organised or economic-financial crime;
15. >Other serious infringements.

2.2. Issues related to the following matters, among others, shall not be considered infringements and, for this reason, shall not be communicated through the Whistleblowing Channel:

1. a) Complaints related to the quality of the services provided by the Company;
2. Day-to-day queries or issues concerning the normal dynamics of the employment relationship (such as, for example, scheduling and changing holiday periods, justifying absences, queries about receipts, etc.);
3. c) Incidents relating to damage to premises or equipment, natural disasters or terrorist attacks;
4. d) Personal or legal disputes;
5. Events that pose an immediate threat to life or property.

2.3. Any infractions submitted that do not fall within the scope identified in paragraph 2.1 above will not be dealt with under this Policy, even if they do not fall within the categories set out in the previous paragraph.

2.4. This policy does not prevail over the obligation to report in the cases and under the terms determined by the criminal law and criminal procedure.

3.1. Within the scope of this policy, and in accordance with the law, whistleblowers (“Whistleblowers”) are considered to be those who, in good faith and having serious grounds to believe that the information is true, report an offence of which they have become aware in the context of their professional activity and/or relationship with Super Bock Group companies, even if the information was obtained in the context of a professional relationship terminated in the meantime, or during the recruitment process or during another pre-contractual negotiation phase of an existing or unformed professional relationship.

3.2. For the purposes of the preceding paragraph, the following may be considered as Whistleblowers:

1. a) Employees, interns and volunteers from Super Bock Group companies;
2. b) Service providers, suppliers, clients and all those who, directly or indirectly, maintain a contractual or pre-contractual relationship with Super Bock Group companies;
3. Holders of shareholdings and persons belonging to the administrative or management bodies or to supervisory bodies, including non-executive members, of companies in the Super Bock Group.

4.1. This Policy is supported by the Company’s Whistleblowing Channel, which will be used to receive, process and deal with reports of potential infringements.

4.2. he Whistleblowing Channel is available on the Company’s internal and external communication channels, namely the intranet and the corporate website.

4.3. The Whistleblowing Channel is managed by an external and independent entity, which will be responsible for ensuring the receipt, screening and preliminary analysis of the complaints received under the terms of this Policy.

4.4. Access to the information made available by the Whistleblowers through the Whistleblowing Channel is limited to the persons with the competence to handle it in order to ensure the confidentiality of the reports.

4.5. The Whistleblower may select the degree of confidentiality with which he/she wishes to submit a report of possible infringement. Such communication may contain the identification of the Whistleblower or be totally anonymous. However, given that confidentiality is always ensured, the identification of the Whistleblower is recommended, as this speeds up the enquiry process and facilitates contact.

4.6. The communication shall contain the details necessary for the subsequent handling of the complaint, including a description of the facts supporting the alleged infringement.

4.7. As part of the internal complaint, the Whistleblower will be notified in accordance with the following deadlines:

1. a) Within 7 days from the date of receipt of the complaint, on the receipt of the complaint and on the requirements, competent authorities and form of admissibility of the external complaint, if applicable;
2. Within 3 months from the date of receipt of the complaint, on the measures envisaged or taken to act on the complaint and their justification.

4.8. The Whistleblower has the right to rectify their complaint, as well as to change it on the basis of supervening facts. This right should be exercised through the same channel initially used for the initial communication.

4.9. Considering the existence of an internal Whistleblowing Channel, the Whistleblower may not previously resort to external whistleblowing channels or publicly disclose the infraction, except in the cases provided for in Article 7(2) and (3) of Law no. 93/2021 of 20 December.

4.10. A Whistleblower who, outside the cases provided for by law, becomes aware of an infraction under the terms of the preceding number shall not benefit from the protection conferred by law.

4.11. Super Bock Group reserves the right to refuse to handle complaints whose contents exceed the scope of the matters covered by this Policy or that do not contain a description of the facts supporting the alleged infraction, selecting only those that meet sufficient grounds for an enquiry and that are related to the object of the Policy, excluding complaints that have clearly been filed in bad faith.

5.1. Reports of potential infractions will be subject to a process of enquiry and investigation unless they are manifestly unfounded, the information provided is insufficient or the matter reported is excluded from the scope of this Policy.

5.2. Investigations are initiated by an external and independent entity, through a preliminary analysis of the completeness of the information provided by the Whistleblower, as well as an assessment of whether the complaint falls within the scope of this Policy.

5.3. If the communication falls within the scope of the Whistleblowing Channel, and the information provided allows the investigation to be started, it will be sent by the external entity to the Ethics Committee of the Super Bock Group for subsequent evaluation and treatment.

5.4. Should the complaints presented involve any member of the Ethics Committee or members of the Board of Directors, these will be forwarded by the external entity to the Supervisory Board.

5.5. The analysis mentioned in the preceding paragraph will be:

1. Confidential;
2. Documented in a report, on which Company officials must decide whether to close the report or subject it to further investigation.

5.6. In the event of a conflict of interest regarding the content or subjects of the potential violation and the participants in its analysis or investigation, they will not have knowledge of the communication, and the process of analysis and processing will be attributed to other participants who do not present a conflict of interest.

6.1. In the enquiry process all the facts necessary to assess the alleged infraction shall be verified, and the body responsible for this process may be supported in it by other bodies, departments or employees of the Super Bock Group, whenever necessary, or even by external auditors or other experts contracted to assist in the investigation.

6.2. The enquiry process shall end either with the closure of the case or with a proposal to apply measures appropriate to the infringement in question. Upon completion of the enquiry process, a report will be produced with findings and:

1. a) Measures necessary to correct the infringement and, where applicable, the respective disciplinary sanction;
2. b) Indication of the non-adoption of any measures, with the reasons for non-implementation duly substantiated;
3. Communication to external entities, whenever justified.

7.1. Reports of infringements under this policy are always treated as confidential information.

7.2. Confidentiality covers, in particular, the identity of the Whistleblower, the facts reported and the identity of any third parties mentioned in the complaint.

7.3. All those who have access to information contained in the enquiry processes concerning alleged infractions shall be obliged to keep it confidential.

8.1. Reports of violations that fall within the scope of and are made in accordance with this Policy may under no circumstances be subject to any prejudicial treatment, retaliatory action, harassment, intimidation or discrimination of the Whistleblower by the Company’s management or any employee.

8.2. An act of retaliation is considered to be any act or omission (even if in the form of a threat or attempt) that, directly or indirectly, occurring in a professional context and motivated by an internal or external report or public disclosure, causes or may cause economic or non-monetary damage to the Whistleblower who, in good faith, and having serious grounds to believe that the information is, at the time of the report or public disclosure, true, reports or publicly discloses an infraction.

8.3. Non-retaliation extends, mutatis mutandis, to:

1. A natural person who assists the Whistleblower in the complaint procedure and whose assistance must be confidential, including trade union representatives or workers’ representatives;
2. Third parties connected to the Whistleblower, such as work colleagues or family members, who may be the target of retaliation in a professional context;
3. Legal persons or similar entities that are owned or controlled by the Whistleblower, for which the Whistleblower works or with which he/she is in any way connected in a professional context.

8.4. Without prejudice to the provisions of the preceding paragraphs, whenever reports are made in bad faith or based on information or elements that the Whistleblower knows, or cannot be unaware of at the time of the report, are false, the Company may determine the opening of disciplinary proceedings against the Whistleblower, in the case of an employee, or to apply a contractual penalty/resolution, appropriate and proportional to the infraction, if the Whistleblower is a service provider, supplier, customer or other, without prejudice to the possible civil and/or criminal liability that may arise for the perpetrator of such conduct.

8.5. There must be a close link between the complaint and the unfavourable treatment suffered, directly or indirectly, by the Whistleblower, for such unfavourable treatment to be considered an act of retaliation and, consequently, for the Whistleblower to benefit from legal protection in this context.

9.1. The information and personal data collected through the Whistleblowing Channel will be processed by Super Bock Bebidas S.A., as the Data Controller, within the scope and for the purpose of the process of analysis and response to the communications of violations reported through it, in accordance with the following legal bases:

1. Compliance with legal obligations imposed on Super Bock Group companies, namely regarding the mandatory implementation of a whistleblowing channel, under the terms established in Law no. 93/2021 of 20 December and Decree Law no. 109-E/2021 of 9 December;
2. b) Pursuit of legitimate interests of Super Bock Group companies, namely the knowledge and prevention of infractions occurring in the context of their activity;
3. Consent from the author of the communication who chooses to identify himself/herself before the whistleblowing channel.

9.2. The security of the information provided regarding alleged infringements, and the respective records, is ensured by the internal rules of the Super Bock Group, in compliance with the applicable legislation on data protection and information security.

9.3. The personal data collected will be processed by an external and independent entity, which, assuming the quality of subcontractor, will process such data, in the name and on behalf of the Super Bock Group, during the reception, screening and preliminary analysis of the complaints received.

9.4. The Whistleblower, and any persons who may be identified in the report, are guaranteed the right to access the personal data concerning them and to obtain their rectification or suppression if they are inaccurate, incomplete or ambiguous.

9.5. In the case of the person identified in the communication, the provisions of the previous paragraph shall not apply if and to the extent that the exercise of these rights may conflict with other rights that should prevail, and information on the author of the communication may never be provided.

9.6. The right of access, rectification and deletion of data concerning you under this Article shall be made by means of a written declaration addressed to privacy@superbockgroup.com except where data processing is for the purpose of ascertaining the veracity of suspected criminal offences, in which case the complainant’s right of access shall be exercised through the Portuguese Data Protection Authority (CNPD).

9.7. Under the terms of the personal data protection regulations, the holders of personal data subject to processing have the right to lodge complaints with the CNPD regarding the processing of personal data concerning them.

9.8. The Super Bock Group shall keep a record of the complaints received and shall retain it for at least five years or, regardless of such period, while any legal or administrative proceedings relating to the complaint are pending. However, all personal data that is clearly not relevant for the processing of the complaint will not be kept.

10.1. This policy is published on the Company’s intranet and website.

10.2. This policy comes into effect on the day of its publication.