ETHICAL CULTURE

In business, there is winning at all costs and there is winning the right way. For Molson Coors, the way we do business is what matters most to us. While we celebrate diversity of background and thought, it is our shared values that unite us and guide our actions. No matter where you work in Molson Coors, these values -- Excelling, Passion, Integrity & Respect, Creativity and Quality -- drive everything we do. We firmly believe this is the only way we can achieve our ambition to be a top performing global brewer. When we are living our values, we are performing at our very best, and winning the right way.

This belief is the cornerstone of our Ethics and Compliance program. It’s more than following the rules, it is a reflection of our passion for excelling and acting with integrity. The program is focused on guiding our behavior in a way that is consistent with our values and an ethical culture and has the full support of our senior leadership. Our Audit Committee of the Board of Directors and our internal Ethics and Compliance Committee, comprised of our CEO and his direct reports, help set the direction of our program and hold themselves accountable to the same standards of ethical behavior.

At the heart of our program is the Molson Coors Code of Business Conduct, Living Our Values. Living Our Values or ‘the Code’ is a guide to making decisions that are consistent with our values. It outlines the standards and acceptable behavior for all Molson Coors employees worldwide and, as such, is available in English, French Canadian, Spanish, Chinese and Japanese. All of our employees and our Board of Directors affirm the Code upon joining the organization and biannually thereafter.

In support of the Code, we have an interactive online training tool that helps employees understand what it means to them and how they might apply it every day. All employees receive periodic training on the Code. Additional in-person training focused on ethical leadership and ethical decision-making in key areas of the Code is delivered to targeted employees based on their responsibilities.

Our Code acts as an umbrella of principles under which we have more detailed compliance policies for each business unit. These policies are available to employees on our intranet and training is delivered to target audiences based on relative risk in the organization.

Our employees also have access to an Ethics and Compliance Helpline through Ethics Point via the internet and telephone 24 hours a day. The helpline allows employees, or any stakeholder, to ask a question or raise a concern in their native language in a confidential and/or anonymous manner. All questions and issues raised through this channel are responded to through the Ethics and Compliance Office at Molson Coors.

In 2009, we had 24 reports through this channel as compared to 45 in 2008. The reduction in number of reports was due in large part to the split off of MillerCoors at the end of 2008. This resulted in a reduction of approximately 4,000 employees who previously would have reported issues through our Ethics and Compliance Helpline. Of the 2009 reports where investigative action was necessary, 58% were substantiated and resulted in disciplinary action, up from only 50% in 2008. 38% of reports in 2009 were anonymous vs. 37% % in 2008.

Reports were made in the following categories: