Chapter 1. Definitions.

Article 1.

In these rules (the " Rules ") the following terms shall have the following meanings:

- Employee: a person, employed or otherwise, working for the Company or its subsidiaries;

- Company: the limited liability company Efes Breweries International N.V.

- Chief Executive Officer: the Chief Executive Officer of the Company ;

- Chairman of the Supervisory Board: the Chairman of the Supervisory Board of the Company ;

- Manager: the person directly managing the Employee;

- Confidential Adviser : the person designated by the Chief Executive Officer to act in that capacity for the Company and its group company;

- Suspected Irregularity: a suspicion based on reasonable grounds with regard to the Company and in connection with:

a. an (imminent) criminal offence;

b. an (imminent) violation of laws and regulations;

c. an (imminent) intentional provision of incorrect information to public bodies;

d. a violation of rules of conduct applicable within the Company; or

e. (imminent) intentional suppression, destruction or manipulation of information regarding those facts.

Chapter 2. Procedure.

Article 2.

2.1. Unless an exception applies as referred to in article 5 paragraph 2 of these Rules, Employees shall report suspected irregularities internally to their Manager or, if they consider reporting to the Manager inappropriate, to the Confidential Adviser. They may also report to the Confidential Adviser in addition to the Manager.

2.2. The Manager or Confidential Adviser shall on request make a written record of the report and of the date of its receipt and shall have the Employee concerned sign the record for approval. The Employee shall receive a copy of the record. The Manager or Confidential Adviser shall procure that the Chief Executive Officer shall be informed immediately of a Suspected Irregularity and of the date on which it was reported, and he shall procure that the Chief Executive Officer receives a copy of the record.

2.3. The Chief Executive Officer shall send a confirmation of receipt to the Employee who reported the Suspected Irregularity. The confirmation shall refer to the original report. This shall also apply where the Employee has reported his suspicions to the Confidential Adviser rather than his Manager.

2.4. Immediately after the Employee's report, the Board of Management shall start an investigation into the Suspected Irregularity.

2.5. The Employee who has reported the Suspected Irregularity and the person to whom he has reported shall keep the report confidential. No information shall be provided to third parties in or outside the Company and its group companies without the consent of the Chief Executive Officer. In providing information, the name of the Employee shall not be disclosed and information shall otherwise be provided in such a manner as to safeguard where possible the anonymity of the Employee.