At Carlsberg, we are committed to doing business with integrity, responsibility, honesty and ethics.

SpeakUp is Carlsberg's way of encouraging employees and third parties to report violations of the Carlsberg Code of Ethics and Conduct to us. By reporting, you enable us to resolve issues in an appropriate, prompt and objective manner, thereby making Carlsberg a better place to work for all of us. We take reports of suspected misconduct very seriously.

Issues that can be reported through SpeakUp include:

- corruption and bribery,

- violations of various laws (including competition laws, insider trading, trade sanctions, export controls and data protection and privacy laws),

- accounting manipulation,

- conflicts of interest,

- discrimination,

- (sexual) harassment,

- misappropriation of assets (including theft, misuse of company resources),

- disclosure of confidential information,

- environmental issues,

- health and safety issues, and

- bullying.

Anyone who speaks out in good faith is protected — we will not tolerate any form of harassment against our staff. Harassment of good-faith people is itself considered a breach of our Code of Ethics and Conduct and can have consequences. Any person who deliberately uses the platform to knowingly make false allegations may be subject to disciplinary action.

How to report?

You can speak to your local manager, representatives of Compliance and HR Department or send an email to [email protected]. If you are uncomfortable speaking to them, you can raise your concerns anonymously through our SpeakUp platform, which is maintained by third-party company Convercent. Convercent is an independent company, which is not part of the Carlsberg Group, and this platform allows you to report your concerns anonymously.

Anonymous reporting services operate 24/7 and are available in all languages.

There are two easy ways to report your issue anonymously.

Once you have reported through the Speak Up line

As soon as your request is sent in, it will be immediately reported to the Speak Up verification team at the Carlsberg Group. If you choose to report anonymously, Carlsberg will not provide your personal details.

You will also be provided with a confidential issue access number and will be asked for a personal password and a secret question. The access number and password allow you to check the report status on the external SpeakUp platform and communicate with the SpeakUp verification team without revealing your identity. If you have provided an email address, you will also receive email notifications from the system when your report status is updated.

The Carlsberg Group Speak Up Guidelines explain in more detail how you can report suspected or actual misconduct confidentially and without fear of retaliation. They also describe what you can expect us to do in terms of follow-up actions and taking any necessary measures.

How does Carlsberg investigate misconduct?

Your report will be registered in the case management system (CMS). Depending on the nature and potential impact of the issue, the case will be reviewed by trained professionals within the local organization or by a dedicated SpeakUp verification team, which is part of the Group's Internal Audit. This team works under the supervision and guidance of the Carlsberg Ethics Committee.

The Executive Committee, together with the Supervisory Board, has established an Ethics Committee, chaired by the Group Chief Financial Officer, which is assigned to oversee the investigation of alleged misconduct reported through available channels of communication within the Carlsberg Group. The Ethics Committee reports on SpeakUp matters to the Executive Committee and the Audit Committee at least quarterly.

The SpeakUp Verification Guidelines (available upon request to Speak Up case owners) detail the management of misconduct investigations to ensure they are conducted in a consistent, independent and objective manner. The Guidelines also describe in detail how we conduct investigations that not only maintain confidentiality but also protect the interests and welfare of those assisting in the investigations.