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Q. What is the relationship
between Anadolu Efes and EBI?


A. Anadolu Efes owns 73.5% of EBI which conducts brewing operations in Southeast Europe, Russia and Central Asia.

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RULES OF CONDUCT RELATING TO SUSPECTED IRREGULARITIES OF
EFES BREWERIES INTERNATIONAL N.V.

Article 3.

3.1. Within 8 weeks from his internal report, the Employee shall be informed in writing, by or on behalf of the Chief Executive Officer, of the Board of Management's position with regard to the Suspected Irregularity and the action taken as a consequence of the Employee's report.

3.2. If no position can be given within eight weeks, the Employee shall be notified thereof by or on behalf of the Chief Executive Officer and be given an indication as to when he will be informed of the Board of Management's position.

Chapter 3. Reporting to the Chairman of the Supervisory Board.

Article 4.

4.1. The Employee may report the Suspected Irregularity to the Chairman of the Supervisory Board, if:

a. he disagrees with the position referred to in article 3 of these Rules;

b. he has not been given a position within the requisite period, as referred to in the first and second paragraphs of article 3 of these Rules;

c. the period as referred to in the second paragraph of article 3 of these Rules is, given all circumstances, unreasonably long and the Employee has objected against this to the Chief Executive Officer, but the latter has not indicated a shorter, reasonable period;

d. the Suspected Irregularity concerns a member of the Board of Management of the Company; or

e. an exception as referred to in the next paragraph of this article applies.

4.2. An exception as referred to in the previous paragraph of this article applies if there is:

a. a situation in which the Employee has reasonable grounds to fear that an internal report would lead to countermeasures; or

b. a previous, duly submitted, internal report about essentially the same irregularity, which has not removed the irregularity.