MCBC Speaking Up Privacy Notice

This notice applies to anyone who makes a report through channels provided by Molson Coors Beverage Company (MCBC) to report misconduct in the workplace (the “whistleblowing channels”) and to anyone about whom a report is made through the whistleblowing channels. The data processing described in this notice may be limited as required by applicable law.

Molson Coors’ Ethics and Compliance Helpline (“the Helpline”) is a secure reporting tool our stakeholders can use to report concerns related to potential violations of our Code of Business Conduct, Company policy or the law. The Helpline is hosted by a third-party provider, Convercent, to maintain confidentiality and anonymity when requested and as permitted by law. In some jurisdictions it is required that you provide your name and this is reflected in the reporting tool when you submit a report.

Benefits include:

  1. global confidential access anytime, available online or by telephone in several languages; and
  2. an easily accessible method for employees, external partners and other stakeholders to report a concern.

This notice explains how MCBC collects, uses, and discloses personal data in connection with the Helpline. Personal data means any information relating to an identified or identifiable individual.

Personal Data We Process

MCBC processes personal data through the Helpline to the extent necessary to pursue our legitimate interests in preparing a report, conducting an investigation and responding to the concern. When you submit a report to the Helpline, you will be given a report number that you may use to check the status of the report. In connection with a report, we may collect and process personal data, including the identity of the reporter if the reporter decides not to be anonymous, and the position, location and contact information of:

  1. the individual submitting the report;
  2. the individual who is the subject of the report;
  3. other individuals with information relating to the report; and
  4. the individuals responsible for investigating the report.

In addition, personal data may be included in:

  1. the facts that are reported to the Helpline;
  2. follow-up questions that you may be asked to clarify;
  3. evidence gathered in the course of the investigation;
  4. any reports generated as part of the investigation; and
  5. any response taken by MCBC and its affiliates as a result of the report.

The Helpline is not intended to collect or process sensitive personal data (i.e., information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, data concerning sex life or sexual orientation) or criminal convictions and offences. To the extent such data is intrinsic to the facts that have been reported through the Helpline, we will seek to minimize any resulting collection and further processing of such data.

Lawful basis

We are under a legal obligation to provide whistleblowing channels in certain countries where we operate. Where the report falls under this legal obligation, that will be our basis for processing this data. For any other reports, we rely on our legitimate interests to ensure that the conduct of our employees and other representatives is in keeping with what is required by law, by industry standards and by our internal policies and standards.

Sharing of data/ With whom we may share your data

We partner with a third-party provider (Convercent) who operates the call center and online portal for the Helpline. Convercent collects data relating to reports on our behalf, then passes the reports on to us.

We may share personal data with external consultants contracted to conduct independent investigations. We may also share data with legal counsel to represent us in any type of legal proceedings. We may need to share your personal data if requested by legal or regulatory authority.

Data Transfers

We are a global organization. To the extent permitted by applicable law, your personal data may be transferred to, stored or accessed by MCBC personnel located in Europe, the United States or elsewhere for the purpose of managing the Helpline and investigating an allegation. When your personal data is transferred to (or accessed from) a country outside the EU for which the European Commission has not issued an adequacy decision, we will ensure that appropriate safeguards are implemented to protect your personal data in accordance with applicable laws. This may include (intra-group) data transfer agreements incorporating the European Commission’s Standard Contractual Clauses, pursuant to article 46 of the GDPR, a copy of which you can obtain by contacting us as indicated below.

Security and Retention

We make reasonable efforts to ensure a level of security appropriate to the risk of the data processing and have implemented technical and organizational measures to protect your personal data. After the conclusion of the relevant investigation, we will retain the personal data contained in a Helpline report according to our record retention policies. If the investigation leads to disciplinary or legal proceedings, we may need to retain your personal data until the conclusion of those proceedings and the period permitted under applicable law.

Your Rights

Subject to applicable law, you may have the right to request access to and receive details about the personal data we maintain about you in connection with a report made through the Helpline. You also may have the right to request that certain personal data about you be rectified, erased or restricted, in accordance with applicable law. You also may have the right to object at any time, on legitimate grounds, to the processing of your personal data in the context of a report to the Helpline. We will respond to your questions or complaints relating to the processing of your personal data. If you are not satisfied with our responses, you may consult the data protection authority of your country. The exercise of your rights may be restricted as necessary to protect others in the context of a particular allegation. To exercise your rights please send an e-mail to: [email protected]

No Retaliation

MCBC does not tolerate retaliation by anyone against a person for speaking up in good faith about a potential violation, or for participating in any Company investigation. MCBC will take actions necessary within MCBC to prevent retaliation.

How to Contact Us

If you have any questions or comments about the Helpline, or if you would like to exercise your rights of access, correction, erasure, restriction or objection to the processing of your personal data, please contact [email protected]

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