Sample_COC

code of conduct our people. our values. our success.

Our People. Our Values. Our Success.

an Altria Company

whenever we’re confronted with a situation where the proper course of action is not clear, we should ask ourselves:

is it legal?

does it follow company policy?

is it the right thing to do?

how would it look to those inside and outside the company?

Notes to Our Code: Throughout our Code, “Altria’s companies” or “our companies“ refer to Altria Group, Inc. and its subsidiaries. This Code does not alter the terms and conditions of employment, or constitute express or implied contractual obligations or contracts of employment.

mission our mission is to own and develop financially disciplined businesses that are leaders in responsibly providing adult tobacco and wine consumers with superior branded products.

create substantial value for shareholders

invest in leadership

align with society

satisfy adult consumers

values our values guide our behavior as we pursue our mission and our business strategies.

driving creativity into everything we do

integrity, trust and respect

passion to succeed

sharing with others

executing with quality

letter fromour chairman and chief executive officer

Colleagues:

Of course, no compliance program is perfect. In corporations as large and complex as ours, there will be employees who run afoul of the rules, often unintentionally. Our objective is to have a compliance system and culture that prevents such issues from arising, but also one in which issues get raised early and addressed promptly and effectively when they do occur. In my experience, big problems usually start small, and we can avert them if we identify and address them earlier rather than later. Our commitment to compliance means that we all understand our obligation to prevent issues of non-compliance. We should never see a potential compliance issue and say to ourselves, “That’s not my problem.” This goes against our Values and unnecessarily puts our company at risk. All of us have a duty to seek guidance when we are unsure about the right course of action and to speak up when someone is not acting in compliance with our Code or policies. We are all accountable for upholding the principles in our Code. It applies equally to all of us, regardless of position, and will be enforced fairly across our company. Take pride in your conduct and never compromise your integrity.

Together, our companies have been in business for more than 180 years, through ever-changing and increasingly complex business environments. To continue to be successful, we must run our businesses responsibly and in compliance with all applicable laws. Furthermore, we must hold ourselves to high standards of integrity in all that we do. Our shareholders expect no less. It is up to all of us to pursue our Mission and strategies by fully adhering to our Values and this Code of Conduct. This includes thoroughly thinking through our decisions and actions and basing them on the solid foundation of our Values and commitment to compliance. Our Code of Conduct, Mission and Values, and the Policy Library work together to provide us guidance on how we should approach our work. Our Code is not a prescription, but rather a framework for operating with integrity. It directs us to ask before acting: ■ ■ Is it legal? ■ ■ Does it follow company policy? ■ ■ Is it the right thing to do? ■ ■ How would it look to those inside and outside the company? Our Code applies to all work situations in which we may find ourselves – from conflicts of interest and giving and receiving gifts to adhering to antitrust and unfair competition laws. Specific company policies supplement our Code’s guidance and, when used together, provide direction to make sound decisions. It is our responsibility to know and understand our Code and the policies that apply to our work.

Thank you for your continued commitment to our Mission, Values and Code of Conduct.

Marty Barrington Chairman and Chief Executive Officer Altria Group, Inc.

table of contents

our code

guidance on business operations

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■ ■ antitrust and fair competition ■ ■ communications

■ ■ why do we have a code? ■ ■ who must follow our code? ■ ■ does our code explain all the standards I need to know? ■ ■ what about laws in different countries?

■ ■ environmental compliance ■ ■ importing and exporting ■ ■ political activity and interacting with governments ■ ■ product communication ■ ■ product regulatory and quality ■ ■ research

doing the right thing

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■ ■ our shared responsibilities ■ ■ additional responsibilities for managers and supervisors

guidance on information and records

68

asking questions and raising concerns

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■ ■ intellectual property ■ ■ management, protection and use of company records and information

■ ■ duty to speak up ■ ■ altria’s companies do not tolerate retaliation

■ ■ privacy

employment and workplace guidance

22

waivers of our code

78

■ ■ fair employment ■ ■ health, safety and security ■ ■ workplace conduct

acknowledgement

79

index

80

internal contacts and integrity helpline / webline

85

financial guidance

36

■ ■ fiscal compliance, asset management and cash management ■ ■ procurement and supplier management

our code

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why do we have a code?

who must follow our code?

does our code explain all the standards I need to know?

what about laws in different countries?

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Our Code and the Principles upon which it is based help us to apply our Values in our operations and pursue our Mission responsibly.

Why Do We Have a Code?

The Altria Group Chief Compliance Officer also reviews the compliance program with Altria’s senior officers and the Board of Directors.

■ ■ Our Code introduces us to many important laws, policies and procedures we must follow

Who Must Follow Our Code? Our Code applies to all employees, including senior management and officers, who work for Altria’s companies.

■ ■ It shows us how to spot potential issues in our work

■ ■ It identifies resources when we need more information, want advice or wish to report concerns

Our Code is part of our enterprise-wide compliance and integrity program supported by the Altria Group Board of Directors and officers, and by the management of Altria’s companies.

Does Our Code Explain All the Standards I Need to Know?

Our Code is the cornerstone of our commitment to integrity, but it does not discuss every law, policy or procedure that applies to your work. Your company has more specific policies and procedures on the topics in our Code. You can find much of that

The Altria Group Chief Compliance Officer, compliance officers in our companies, and the Compliance & Integrity department oversee our compliance program.

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