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COMPLIANCE GUIDELINES

COMPLIANCE GUIDELINES. Presented by: Michael Lurie, Senior Vice President and General Counsel Andrew Levy, Associate General Counsel February 13, 2007. LEGAL DEPARTMENT. Michael Lurie, Senior Vice President and General Counsel

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COMPLIANCE GUIDELINES

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  1. COMPLIANCE GUIDELINES Presented by: Michael Lurie, Senior Vice President and General Counsel Andrew Levy, Associate General Counsel February 13, 2007

  2. LEGAL DEPARTMENT • Michael Lurie, Senior Vice President and General Counsel Corporate, regulatory, DISCUS, litigation, compliance, real estate, Canadian issues and other legal or regulatory matters at anytime. (312) 873-9218 • Andrew Levy, Associate General Counsel Wholesaler matters, health benefit plans, employee matters, trademark issues, union negotiations, consumer complaints, contracts, leases, Crown matters, etc. (312) 873-9380 • Robin L. Moncrieff, Associate General Counsel DISCUS, consulting/IT contracts, consumer complaints, wholesaler matters, other contracts, international issues, etc. (312) 873-9209 • Karla Carey, Regulatory Compliance Administrator Liquor licenses, salesperson licenses, bonds, marketing approvals, federal and state regulatory matters. (312) 873-9377 • Apollonia Ponticiello, Legal Department Coordinator Trademark matters, licensing and wholesaler terminations. (312) 873-9378 • Maria Ortiz, Executive Assistant to Legal Department, Consumer Complaints (312) 873-9396

  3. SERVICES • TTB, Customs and State Regulations and Licensing Requirements   • Acquisitions and Dispositions • Supplier Agreements • Other Legal Agreements • Beers and Spirits Wholesaler Matters • Beers and Spirits Advertising/Promotions; Training • Health/Disability Plans • 401(k) and Profit Sharing Plans • Union Matters • Canada • Trademarks • Employee Matters • Trade Groups • Corporate • Litigation • Consumer Complaints • Environmental, Health and Safety • Compliance Guidelines and Record Retention

  4. CROWN JV TRANSACTION • “Go Live” was January 2, 2007 • Transition period until August 1, 2007

  5. CODE OF RESPONSIBLE PRACTICES FOR BEVERAGE ALCOHOL ADVERTISING AND MARKETING • Primarily marketing-related, with the theme that we are not targeting under-21 (“LDA”) individuals • 70% LDA demographic – certifications on the front end and audit on the back end • Models to be over 25 years of age and appear that way • Certain restrictions on campus advertising • Responsible content in terms of no cartoon figures, no irresponsibility, no “rites of passage,” no illegal or dangerous activities, good taste • Age verification on websites

  6. THREE-TIER SYSTEM Supplier – Wholesaler – Retailer • Intended to prevent inappropriate/coercive business practices • Tied House Rules and “Things of Value” • Corona Light “Chill” promotion

  7. YOUR OBLIGATIONS • Abide by the Code • Pre-clear sponsorship agreements with time for Legal to review, and obtain LDA-certification • Pre-clear promotions since every state is different • Risk to the Company and to you as an individual licensed person as well as an employee of the Company • Pre-clearance can be time-intensive, so leave enough time for this • Consider use of intellectual property – if different or for use by a third party • Antitrust issues re. pricing, etc.

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