Anti-Bribery and Corruption Code

William Grant & Sons is a family business that for over 130 years has been guided in its business dealings by a strong belief in morals and business ethics. This belief lies behind our company values of Be Proud, Be Responsible, Be Professional, Be Entrepreneurial, Think Long Term, Be Sustainable and Embrace difference, each of which helps to support and drive our corporate behaviour.

Being Responsible means that we are accountable and Being Professional means ensuring integrity and transparency in our actions and behaviours. As such, we will not tolerate bribery or corruption in any form, and will conduct our business in an ethical and responsible way by adhering to these core principles:

1. We promote an internal corporate culture of ethical behaviour and actively communicate our commitment to anti-bribery compliance to all employees.

2. We comply with the laws and regulations of every country in which we operate and transact.

3. We do not provide, offer or accept bribes, kickbacks, corrupt payments, facilitation payments, inappropriate gifts, to or from public officials or any commercial person or entity, regardless of local practices or customs.

4. We encourage our business partners to uphold the same ethical standards that we abide by and will immediately stop doing business with anyone whom we have reasonable grounds to believe may be involved in any form of bribery.

5. We record all transactions completely and accurately in our accounting and financial records.

6. We maintain a zero-tolerance approach to bribery wherever in the world we do business.

June 2024