Code of Conduct

A tour business decisions are made exclusively in the best interests of the Company. Any conflicts of interest with personal matters or other business or non-business activities, includingthose of relatives or other related parties should be avoided.Should such conflicts nevertheless occur, they must be resolvedin accordance with the law and Group policies. Conflicts must be dealt with openly and transparently.

Compliance with law, rules and regulations is for us an essential basic principle of responsible business conduct. We adhere to legal prohibitions and requirements at all times, even if this involves short-term business disadvantagesor difficulties for theCompany or individuals. Where national laws are more restrictive than the rules applying at Marlboro and its associate companies, the national laws takeprecedence.

We fulfill its legal obligations to prevent money laundering and do not participate in money laundering activities.In cases of doubt, all employees are required to report unusual financialtransactions, especially those involving cash, which could givegrounds to suspect money laundering, to the responsible finance, legal or compliance department forreview.

We take the necessary steps to suitably protect confidential information and business documents from access and inspection by unauthorized colleaguesand other thirdparties

The protection of personal data in particular of employees, customers and suppliers, is of particular importance to all ofour associated companies.We collect and process personal data only when this isabsolutely necessary to perform workrelated tasks or when requiredby law. Personal data may be collected orprocessed only with the consent of the person concerned and where permitted by law.

For us, sustainability, environmental and climate protection and resource efficiency are key corporate objectives. When developing new products and services and when operating production equipment, we ensure that all environmental and climate impacts are kept to a minimum and our products make a positive contribution to environmental and climate protection for ourcustomers.