Introduction

INAB is a beverage manufacturer that operates in several Latin American countries and different cultures. Stay true to our values, was what shaped INAB in these almost 30 years of existence.

As a proud and responsible brewer, INAB is committed to conducting business with integrity and fairness, respecting the laws and our values. This commitment is described in this INAB Code of Business Conduct (''Code of Conduct''), which encompasses the most important principles of ethical conduct that should guide the daily lives of all employees and individuals or entities that act on our behalf.

No financial goals, no sales targets and no effort to outperform the competition outweigh our commitment to ethics, integrity and compliance with applicable legislation.

We recognize that putting our values ​​and this Code into practice is not always easy. You may face conflicting pressures and dilemmas. This could mean that, sometimes, we will need to reconsider our activities or not take advantage of certain business opportunities. We know that making the right decisions requires courage, but we believe that this Code will provide all the necessary guidance for this.

It is the responsibility of all Employees to carefully read and understand this Code of Conduct. Leaders must also ensure that, within their respective areas of responsibility, the Code of Conduct is known and respected, and receive appropriate attention and follow-up. In case of doubt, be open and talk about possible dilemmas with your colleagues, manager, trusted representatives or the Legal department. If you have questions about a possible violation of our Code or underlying policies, report to the Compliance Area (as per item 24 below).

INAB prohibits and will not tolerate any retaliation or threat of retaliation against any Employee who reports such violation.

People are the essence of our Company. Our success starts with you. INAB is a great company and together, remaining true to our values ​​and this Code, we will walk the path to success and a better world.

Saul Brandalise Neto

General Director

Summary

1. What is the code
2. Responsible consumption
3. Culture
4. Environment
5. Health and safety
6. Human rights
7. Discrimination and Harassment
8. Competition
9. Conflicts of interest
10. Anti-Corruption Policy
11. Giveaways, Gifts, Entertainment, donations and others
12. Books, accounting records and controls
13. Intellectual Property and Confidential Information
14. Privacy and Data Protection Policy
15. E-mails, internet and information systems
16. Social networks and instant messaging applications
17. Use of company assets
18. Responsible Communication Code
19. Responsibilities
20. Stories
21. Non-retaliation
22. Disciplinary measures

1. WHAT IS THE CODE

The Code communicates the basic principles that each of us needs to observe when acting on behalf of the Company. Explains what we are committed to and what we expect from you as an employee.

The Code applies to all people employed by INAB, regardless of the type of contract or location of your work, including people who work under a third-party contract.

The Code does not cover all situations that may occur, nor do they eliminate the need to act with good professional judgment. We hope that you will always act attentive to your reputation and that of INAB.

2. RESPONSIBLE CONSUMPTION

As one of the main beer manufacturers in Latin America, We promote moderate consumption of our products as part of a balanced and healthy lifestyle.

We market and sell our brands responsibly and work with partners to reduce harmful consumption, how to drink excessively, drinking and driving, drinking during pregnancy and underage drinking. We are all ambassadors for responsible consumption.

That way, We do not tolerate any level of impairment of activities due to excessive or inappropriate consumption of alcohol during working hours or while carrying out our business, and we do not tolerate our Employees operating or driving motor vehicles, inside or outside working hours, if they have consumed alcohol.

If you choose to consume alcohol, do it in moderation, at the right time, in the right place and for the right reasons. Always respect the minimum drinking age and always respect local alcohol intake limits when driving. Anyway, we recommend that you: know how to drink, never direct.

3. CULTURE AND ETHICS

All Employees must strictly comply with all laws, applicable regulations and policies, including this Code of Conduct, and always observe the highest standards of business ethics.

The Company's reputation for honesty and integrity is one of our most valuable assets.

We are a company where all employees behave honestly, objective and diligent in carrying out their duties and responsibilities. The company trusts its Employees to demonstrate professionalism in all matters related to INAB and not participate in any illegal activity or activity that violates the terms of this Code of Conduct and other applicable policies.

All relationships with our customers, suppliers, competitors, organs, government officials and representatives must be guided by compliance with all applicable laws and regulations, including, but not limited, anti-corruption and competition legislation, as described below in this Code, in addition to laws and regulations relating to exchange controls and anti-money laundering (for more information, see Anti-Corruption Policy).

No Employee has the authority to request any action that violates this Code of Conduct, which is not subject to any type of waiver or exception, whether due to commercial or competitive demands, industry practices or other requirements.

All leaders are responsible for applying and enforcing our policies, including distributing and making them available to your teams, including when there is any change.

Any Employee who deliberately violates this policy or authorizes or permits its violation by a subordinate will be subject to disciplinary action., including your termination.

4. ENVIRONMENT

We work hard to achieve a high standard of environmental performance. We believe it is our responsibility to actively reduce our impact on the environment. Our ambition is to expand our business while respecting people and the planet. Within our entire value chain and wherever we operate, we pay specific attention to reducing our CO2 emissions and water consumption, energy and raw materials, and increased use of renewable energy. We also focus on reducing waste through recycling and reuse.

5. HEALTH AND SAFETY

We consider that physical integrity, The safety and health of our employees at work are as important as any other activity and objective of INAB.

People are the essence of our Company. This means we always put health and safety first. We all have a duty to work safely, whether we are at our workplace, visiting places, meeting with clients or traveling, We must always follow safety standards and procedures.

We take the necessary measures to ensure that the following occupational health and safety objectives are met:

1. a) Provide and maintain safe and healthy workplaces.
2. b) Provide and maintain an appropriate work environment.
3. c) Develop a safety culture among workers.

Make sure you know what to do if an emergency occurs at your workplace or anywhere you are visiting. Always follow safety standards to prevent loss of life and report any incident, unsafe situation or near accident.

6. HUMAN RIGHTS

At INAB we recognize that Human Rights are the set of prerogatives based on human dignity, whose effective implementation is essential for the integral development of the person.

We expect you to ensure we meet our Company's commitments to human rights. We recommend that you, just like our customers, suppliers, business partners and others affected by our activities, Report if you observe or suspect possible human rights violations.

7. DISCRIMINATION AND HARASSMENT

Respect for diversity, authenticity and personhood is an essential pillar of our Culture. That's why, INAB promotes and values ​​initiatives in favor of diversity and equality in the workplace, prohibiting all forms of discrimination, whether by race, religion, gender, sexual orientation, age, political opinion, nationality, social position, origin or other.

Decisions related to hiring, benefits, promotions, trainings, disciplinary measures and terminations, should be taken solely based on the skills and performance of Employees.

In the same way, INAB does not tolerate any type of aggression or harassment, be it physical, psychological, moral or sexual.

8. COMPETITION

We strive to win, but we always compete in accordance with competition laws. Our commercial relationships with customers and suppliers, as well as occasional contacts with competitors, require careful attention to competition law rules applicable everywhere we operate.

We do not participate in any agreements with customers, suppliers or competitors, that seek to limit the free action of the forces of the markets in which we operate.

When we have contact with competitor representatives, we show a professional attitude, complying with the principles and Values ​​of the company we represent, and we take care of our personal image and that of INAB.

We do business fairly, based on our ethical principles and in compliance with competition laws in the countries in which we operate.

9. CONFLICT OF INTEREST

Each of us has the responsibility to make decisions for the benefit of our Company, without being influenced by personal considerations. It is important to avoid situations that could create a conflict between the Company's interests and your personal interests.. We must avoid, even, an apparent conflict.

We do not accept that professional decisions are based on personal relationships and interests, so seek guidance and try to be transparent. In many cases, Conflicts can be resolved in an open discussion.

A conflict of interest is not necessarily a violation of the Code of Conduct, but not reporting it is!

If there is a conflict of interest, or appearance of a conflict of interest, be transparent and discuss it with your colleagues, manager, Legal department or trusted representative.

10. ANTI-CORRUPTION POLICY

INAB's policy is zero tolerance to any and all acts of corruption. Like this, Employees must comply, and ensure that our business partners comply, with local and international laws prohibiting corruption everywhere we operate, including Law no. 12.846/2013 (“Brazilian Anti-Corruption Law”) and its regulations, and other applicable national and international laws relating to bribery and corruption, as well as the standards, INAB's internal policies and procedures.

Our Employees and business partners are strictly prohibited from, directly or indirectly, promise, offer or give undue advantage to an official or public body or to any third party on behalf of INAB (in addition to cash and equivalents, may be considered “undue advantage”: product donations, gifts, entertainment (tickets), accommodation, snack, travel expenses, or any other asset of tangible or intangible value).

Small payments requested by a public official with the aim of accelerating or ensuring the performance of a non-discretionary governmental procedure or action (“facilitation payments”), are strictly prohibited under this Code of Conduct, even if non-payment generates losses for INAB.

To ensure compliance with our Anti-Corruption Policy, never hire a third party who can, even if eventually, interact with a public official or body on behalf of INAB (Intermediary) without due prior approval from the Compliance Area.

11. GIFTS, GIFTS, ENTERTAINMENT, DONATIONS AND OTHERS

We offer and accept gifts, entertainment, hospitality and donations to charities in an appropriate and transparent manner, randomly, and never to unduly influence commercial decisions.

We work with our customers, suppliers and other business partners to grow together. This also involves creating a good image with customers, promoting lasting business relationships and demonstrating recognition. Hosting and participating in events that contribute to bringing fun to life are fundamental to our business. Nonetheless, gifts, entertainment and hospitality should never influence or appear to influence the integrity of business decisions or the loyalty of those involved.

If you give or receive gifts, business meals, entertainment or hospitality, ensure it is adequate and proportionate. Offer or accept the offer openly and unconditionally. Always protect our reputation, make decisions with professional criteria and avoid undue pressure on the beneficiary.

Wherever we do business, we respect social and cultural traditions, but we do not make contributions to politicians or political parties. We donate to charities, but always in a transparent and professional way.

12. BOOKS, ACCOUNTING RECORDS AND CONTROLS

We register, in an integral way, correct and timely accounting and financial information in accordance with current accounting regulations, as established by applicable laws and regulations regarding securities, ensuring the veracity of the indicators under our responsibility.

No Employee shall engage in the falsification of any accounting or other business record, and must answer completely and correctly any questions made to them by INAB's internal or external auditors or by auditors from any regulatory authority.

Any Employee who has knowledge of – or information relating to – any unregistered fund or asset or any type of violation of INAB policy on financial data and business operations, must promptly report such matter to your Supervisor or the Compliance Area.

13. INTELLECTUAL PROPERTY AND CONFIDENTIAL INFORMATION

We respect and protect intellectual property and confidential information. We do not disclose any type of confidential information, including those related to industrial and intellectual secrets, processes, methods, strategies, plans, projects, technical data, market or any other type.

We maintain the confidentiality of such information even when our employment relationship has ended., as well as the confidential information of companies we have previously worked with.

14. PRIVACY AND DATA PROTECTION POLICY

We protect the privacy and personal data of our employees, customers, consumers, suppliers and other business partners.

We respect and protect everyone's privacy. We are committed to complying with all relevant data privacy requirements in the countries where we operate.

Therefore, It is important that we all ensure that the handling of personal data or other data that may be related to a person, be done with care and only for the intended business purpose, in accordance with applicable laws and our own privacy standards.

15. E-MAILS, INTERNET AND INFORMATION SYSTEM

Our systems, internet, e-mails, and all data that travels through INAB networks and systems, belong exclusively to INAB. Under no circumstances may our systems be used to send or receive discriminatory or harassing messages, material obsceno, commercial solicitations or that otherwise violate this Code of Conduct.

All messages sent or received through these means are the property of INAB, the Company may, if permitted by local law, monitor and use them for purposes of verifying compliance with laws and internal regulations.

Be careful when using emails, as they have the same legal effect as other written communications. When communicating via email, you must be judicious and write carefully, awareness and precision, avoiding the use of ambiguous language in communications.

Both physical access to INAB facilities and access to our systems are granted based on your role within the Company, being, therefore, personal and non-transferable. Only people who have been explicitly granted username and password access are allowed into our facilities and systems. The information entered, generated or changed in the systems as well as the approvals carried out are the sole responsibility of the electronic user who accessed the system. Therefore, It is prohibited to disclose, give or share your passwords with others, whether temporarily or permanently. Due to the exposure to risk that sharing an access password causes, this conduct may subject the Employee to internal disciplinary sanctions.

16. SOCIAL NETWORKS AND INSTANT MESSAGING APPS

A internet, social networks and instant messaging applications have changed the way we work, offering new ways to relate and communicate with Employees, business partners, customers and consumers, as well as the world at large. Frankness and transparency are part of our culture, and we encourage the exchange of ideas. However, Disclosing confidential or inappropriate information through social media could harm our brands, our Company and our Employees. Furthermore, cases of discrimination, harassment, injury, Defamation and slander on social media or instant messaging applications also goes against our principles.

According to our culture, The following guidelines must be followed by all Employees:

1. Do not express opinions implying or implying that these are official INAB positions.
2. Do not disclose or share images without express authorization, videos or internal INAB information, that have not been disclosed on our own official channels, including photos or videos of documents, training and internal meetings, financial information, process-related information, strategic planning, projects, goals, commercial projections, information about customers, etc.
3. Do not share with people outside the Company messages that you receive in your corporate email and that contain internal content.
4. Do not expose information about our customers, partners and suppliers
5. Do not attack or defame, in person or in a group, anyone, product, customer, supplier, another Employee, former Employee, competitor or any other party related to the Company.
6. Finally, ponder what you want to communicate about yourself. Protect your personal information, because what you publish or reveal about yourself on social networks affects your image and that of the Company. Consider further whether the matter has any connection with the Company's products, public bodies or our competitors.

Common sense always comes first. Please ensure that any feedback you generate is consistent with your work and our Company's professional values ​​and standards. Consider that your profile may be being viewed not only by your colleagues, but also by our customers. By being careful you will be protecting INAB and your personal image!

17. USE OF COMPANY ASSETS

All Company assets, including our assets (information, equipment, vehicles, computers, software), resources, funds, facilities, guys, trademarks and the name of the Company, should only be used for legitimate business purposes. Company assets also include your time at work and the product of your work.

All Employees must protect the Company's assets and ensure that such assets are well managed and used efficiently. Company assets cannot be used for personal purposes, unless expressly authorized in specific policy

We have a responsibility to protect and properly use INAB’s assets, as well as seeking the best use of the resources allocated.

18. RESPONSIBLE COMMUNICATION CODE

To protect our Company's reputation, We need to ensure that our communication is done correctly, in the right place, at the right time and for the right audience, under any circumstances. When communicating externally, or if you wish to be involved in speaking on behalf of the Company, You are expected to follow our internal policies and act as an ambassador(a) and INAB.

Please remember that any online communication, including on social media, regarding our brands, may affect the reputation of our Company and our brands. When to use social media, whether during or after working hours, do it responsibly, always act with good professional sense.

19. RESPONSIBILITIES

We expect you to act in accordance with the law, with our Code and its underlying policies, under any circumstances. The laws will always prevail, more restrictive self-regulatory regulations or agreements.

We hope that everyone promotes a culture of openness in which they feel comfortable asking questions and sharing impasses and concerns regarding the interpretation or compliance with this Code.

Professionals who occupy management positions have more responsibilities: you have an essential role to play in maintaining our reputation and license to operate. You are expected to lead by example and create a transparent and open environment, in which concerns or suspicions can be reported without fear of retaliation.

20. REPORTS

The INAB, our values ​​are an essential and indispensable part of life and culture, therefore, We take seriously any report of illegal practices or inappropriate behavior detected in our company.

We keep the reports received by INAB directors from their employees and third parties completely confidential., or those collected through the Compliance Channel or by any other means, unless it is mandatory to disclose part or all of the content of the report and/or the corresponding research, in compliance with applicable legislation.

We do not tolerate unfounded and bad faith reports made to an innocent person.

To determine that a person has performed an act or omission that violates the Code of Conduct and Corporate Policies, we carry out an objective and well-founded investigation, that supports the attribution of responsibility to the person investigated.

Do not report any violation of this Code of Conduct and/or Corporate Policies, of which there is knowledge, implies being conniving and will be subject to corrective action.

We attend to and document all reports received through the Compliance channel.

21. NON-RETALIATION

INAB prohibits and will not tolerate any retaliation or threat of retaliation against anyone who reports a possible violation of the law, Company regulation or policy. In the same way, any Employee who discourages or impedes another person, both to make a report and to seek assistance necessary to report the problem, will be subject to disciplinary action.

Retaliation is a violation of our policies and can be reported to our Compliance Channel and, consequently, may result in disciplinary measures.

We attend to and document all reports received through the Compliance channel.

22. DISCIPLINARY MEASURES

Violations of this Code of Conduct will be subject to corrective action.

The severity of corrective measures will depend on the severity of the errors committed.

Corrective measures range from written warning, resignation, up to criminal proceedings before the competent authorities.

We consider it a violation of this code to not apply corrective measures to non-compliance with it..

We respect the rights of the people involved in the reports received and validate and document all available evidence before taking any corrective action.